Identifying and responding to factors related to harming Minors 8
Principles of safe relations between the Employer’s Personnel and Minors
Minors with special educational needs, including Minors with disabilities 12
Dissemination of knowledge about the Standards for the Protection of Minors 12
Obligations of the persons responsible for the introduction and implementation of the Standards for the Protection of Minors 13
These Standards for the Protection of Minors have been developed in performance of the legal obligation introduced by the Polish Law of 13 May 2016 on Combating Sex Crime and on the Protection of Minors (Journal of Laws of 2024, item 506) with respect to all entities carrying out educational activities.
The overriding principle for all of the actions taken by the Personnel of Andea is to act for the good of Minors and in their best interest. Every member of the Personnel is required to treat Minors with respect, consider their needs, and oppose any and all forms of violence and abuse towards a Minor. To this end, the Personnel of Andea shall act in accordance with the applicable legal regulations and within their competences.
This document applies to all members of the Personnel, the Minors completing vocational and/or pupil internships at Andea, and the Legal Guardians of these Minors. These Standards for the Protection of Minors are generally available at Andea’s website: www.andea.com. Additionally, the members of the Personnel and Minors can access this document in the Guidelines & Policies folder.
“Employer/Andea” shall mean the Andea Group, i.e., ANDEA sp. z o.o. of Kraków and the companies based in Poland in which it holds a majority of the shares, both directly and indirectly. The current list of the members of the Group is available at https://www.andea.com/company-entities/ and in the “Guidelines & Policies” folder that is available to all members of the Group’s Personnel.
“Personnel” shall mean the managers, employees (persons rendering work for the Employer under an employment relationship, hired for a fixed term or under an open- ended contract), contractors, and posted employees, both those working at the Employer’s offices and those working remotely.
“Workplace” shall mean the location where the members of the Personnel carry out work
for the Employer, currently located in Kraków at ul. Kapelanka 42B.
“Principal” shall mean the principal of the school attended by a pupil who completes vocational learning or a pupil internship at the Employer’s in accordance with legal regulations on education.
“Minor” shall mean every person who is under the age of 18 or a pupil of a school that offers learning a trade under an agreement for learning a trade or an employment contract/civil law agreement in order to vocationally prepare the pupil or that offers pupil
internships, as referred to in Article 121a(1) of the Polish Law on Education, under pupil internship agreements.
“Legal Guardian” shall mean a statutory representative of a Minor: a parent 1 or a guardian, 2 a foster parent, 3 or a temporary guardian 4 (i.e., a person authorized to represent a Minor who is Ukrainian and stays in Poland without being under the care of an adult).
“Parental Consent” shall mean the consent of at least one of the Minor’s parents; if the parents do not reach an agreement, they are to be informed that the case will have to be settled by a family court. “Guardian’s Consent,” “Foster Parent’s Consent,” and “Temporary Guardian’s Consent” shall be defined accordingly.
“Vocational/Pupil Internship Coordinator” shall mean the person appointed by the
Employer to manage vocational or pupil internships.
“Vocational Learning Instructor” – the Employer or a person employed by the Employer who holds the necessary professional and pedagogical qualifications for organizing vocational learning at the Workplace.
“Harming a Minor” shall mean any behavior towards a Minor that constitutes a violation of legal regulations. In addition, harm shall also mean neglect (intentional or not), an action, or an omission and any outcome thereof resulting in a violation of the rights, including personal rights, and freedoms of the Minor and a disruption of their development.
The fundamental forms of causing harm are as follows:
physical violence – intentionally causing bodily injury, causing pain or threatening to cause a bodily injury; physical violence can result in fractures, bruises, cut wounds, burns, and internal injuries;
emotional abuse – repeated humiliation, degradation, and ridiculing of a Minor, drawing a Minor into a conflict between adults, manipulating a Minor, lack of appropriate support, care, and love, setting a Minor requirements and expectations the Minor is unable to meet; the intention is to violate personal dignity;
sexual abuse – any behavior that leads to sexual satisfaction at the expense of a Minor; sexual abuse concerns behaviors related to physical contact and behaviors that do not involve physical contact (e.g. showing pornographic materials to a Minor, voyeurism, exhibitionism);
neglect – failure to satisfy the fundamental material and emotional needs of a Minor by a parent or Legal Guardian; failure to provide a Minor with appropriate food, clothing, shelter, medical care, and safety; lack of supervision over a Minor’s compulsory school attendance;
bullying – various forms of abuse from peers. This concerns direct and indirect actions as well as actions taken through communication technologies (e.g. online or through a mobile phone). Bullying occurs when an action is intended to cause distress or harm (intentionality), is regular in nature (repeatability), and the victim is weaker than the perpetrator or a group of perpetrators.
“Online Safety Coordinator” shall mean the member of the Personnel appointed by the Employer as the person responsible for ensuring safe conditions for the Minors to use ICT networks, including the Internet, at the Workplace. If the member of the Personnel appointed by the Employer is absent, they shall be substituted by another person appointed to fill in for them.
“Person Responsible for the Standards for the Protection of Minors” shall mean the Employer or a member of the Personnel appointed by the Employer, exercising supervision over proper application at the Employer’s of the Standards for the Protection of Minors and making sure that the Standards are up-to-date. If the member of the Personnel appointed by the Employer is absent, they shall be substituted by another person appointed to fill in for them.
“Person Responsible for Receiving Reports” shall mean the Employer or a member of the Personnel appointed by the Employer, responsible for receiving reports of events posing a threat to a Minor. If the member of the Personnel appointed by the Employer is absent, they shall be substituted by another person appointed to fill in for them.
“Person Responsible for Interventions” shall mean the President of the Management Board as the person responsible for intervening with the relevant authorities or institutions. If the President of the Management Board is absent, they shall be substituted by a Member of the Management Board.
“Person Responsible for Providing Support to Minors” shall mean a member of the Personnel appointed by the Employer to develop a plan of supporting the Minor once it has been identified that the Minor was harmed and to monitor the implementation of the plan. If the member of the Personnel appointed by the Employer is absent, they shall be substituted by another person appointed to fill in for them.
“Register of Interventions” shall mean the documentation that contains a register of the disclosed or reported incidents or events posing a threat to the well-being of a Minor, containing the following:
a report specifying the reporting person;
the details of the person(s) suspected of causing harm (the Minor’s Legal Guardian, a
member of the Personnel, another Minor, another person);
the type of intervention taken;
the date of the intervention;
the documents produced during the intervention (including memos, intervention sheets, copies of notifications/requests sent to the relevant services/school).
“Minor’s Personal Data” shall mean the minimum scope of information allowing for identifying the Minor.
1 As defined in Article 98 of the Polish Family and Guardianship Code (Journal of Laws of 2023, item 2809), hereinafter
referred to as the “Family and Guardianship Code.”
2 As defined in Article 155 of the Family and Guardianship Code.
3 As defined in Article 1121 of the Family and Guardianship Code.
4 As defined in Article 25 of the Polish Law of 12 March 2022 on Assistance Provided to Ukrainian Citizens in Connection with the Armed Conflict in Ukraine (Journal of Laws of 2024, item 167, as amended).
The Employer has appointed the following persons to perform the functions specified in these Standards:
|
# |
Area of responsibility |
First and last name/function (including substitutes) |
Contact details |
|
1 |
Online Safety Coordinator |
Bartłomiej Buczek, IT Manager |
536-536-933 |
|
Sebastian Tetlak, Senior Security Administrator |
536-536-455 |
||
|
2 |
Person Responsible for the Standards for the Protection of Minors |
Kamila Zawojak, Manager – HR & Recruitment |
536-536-066 |
|
Małgorzata Beltran Szwed, Senior Finance and Compliance Manager |
536-536-150 |
||
|
3 |
Person Responsible for Receiving Reports |
Małgorzata Korzec, Senior HR & Recruitment Specialist |
536-536-124 |
|
Justyna Kaczmarek, Compliance Specialist |
536-536-240 |
||
|
4 |
Person Responsible for Interventions |
Grzegorz Fura, Member of the Management Board |
536-536-885 |
|
Łukasz Górka, President of the Management Board |
501-596-699 |
||
|
5 |
Person Responsible for Providing Support to Minors |
Kamila Zawojak, Manager – HR & Recruitment |
536-536-066 |
|
Małgorzata Korzec, Senior HR & Recruitment Specialist |
536-536-124 |
In terms of protection of Minors, the Employer shall closely cooperate with the schools at which Minors complete their vocational training.
In terms of the actions related to the protection of Minors, the Employer may cooperate with:
health care facilities;
Social Welfare Centers;
psychological/pedagogical counseling centers;
the District Family Assistance Center;
the Police;
the District Court.
If necessary, the Employer informs the Minors staying at the Workplace about the assistance provided by:
the Ombudsman;
the Children’s Ombudsman, including in the form of a trusted phone line: 800 12 12 12;
the trusted phone line for children and the youth: 116 111; and, if necessary, engages in cooperation with these entities.
The Employer shall take actions in order to prevent harm to Minors, including but not limited to:
specifying the principles of responding to risk factors and symptoms of harm being done to Minors;
specifying the principles of safe recruitment of the members of the Personnel;
ensuring that the members of the Personnel who perform the function of a Vocational/Pupil Internship Coordinator or a Vocational Learning Instructor are properly prepared;
specifying the responsibilities of the members of the Personnel;
specifying the principles of safe relations between the members of the Personnel and Minors and among Minors themselves.
The members of the Personnel acting as a Vocational/Pupil Internship Coordinator and a Vocational Learning Instructor shall have at least fundamental knowledge of risk factors and symptoms of harm being done to Minors and, as part of their duties, shall pay attention if those factors or symptoms are present.
If risk factors are identified, the Vocational/Pupil Internship Coordinator or the Vocational Learning Instructor shall reach out to the Minor’s Legal Guardians, providing information about the available forms of support and motivating them to look for assistance from other institutions/entities that act for the good of Minors. All of the steps taken should be documented in the manner adopted at the Employer’s.
5 The relevant Social Welfare Center is determined based on the Minor’s address of residence.
Prior to appointing a member of the Personnel as a Vocational/Pupil Internship Coordinator or a Vocational Learning Coordinator, the Employer shall exercise utmost diligence in terms of preparing that person to perform this function and to work with Minors. The Employer shall also verify if that person is entered into the Register of Sexual Offenders (the limited access register and the register of persons with respect to which the State Commission for Preventing Sexual Abuse of Minors Under the Age of 15 has issued a decision on entering them into the Register) 6. The printout from the Register should be kept in the employee’s file or in another documentation concerning the member of the Personnel.
Prior to being appointed to perform the function referred to in section 5.2.1, the person referred to in section 5.2.1 shall provide the Employer with information from the National Criminal Register with respect to the criminal offenses specified in Chapter XIX (criminal offenses against life and health) and Chapter XXV (criminal offenses against sexual freedom and decency) of the Polish Criminal Code, in Articles 189a and 207 of the Polish Criminal Code, and in the Polish Law of 29 July 2005 on Combating Addiction to Narcotics (Journal. of Laws of 2023, item 1939) or with respect to criminal offenses specified in foreign legal regulations that correspond to the above criminal offenses.7
If the person referred to in section 5.2.1 is a citizen of a country other than Poland, they shall additionally provide the Employer with information from the criminal register of their country of citizenship, which they shall obtain for the purpose of professional or volunteering work that involves contacts with Minors.
The person referred to in section 5.2.1 shall make to the Employer a representation concerning the country or countries in which they resided in the last 20 years, if different than Poland and their country of citizenship, and shall provide the Employer with information from foreign criminal registers, which they shall obtain for the purpose of professional or volunteering work that involves contacts with Minors.
If the legal regulations of the country referred to in section 5.2.4 or in section 5.2.5 does not provide for issuing information for the purpose of professional or volunteering work that involves contacts with Minors, information from that country’s criminal register shall be provided instead.
If the legal regulations of the country from which the information referred to in sections
5.2.4 and 5.2.5 is required do not provide for issuing such information or if that country does not have a criminal register, the person referred to in section 5.2.1 shall make a representation in this respect, stating that they have not been convicted, in that country, of a criminal offense corresponding to the criminal offenses specified in Chapters XIX and XXV of the Polish Criminal Code, in Articles 189a and 207 of the Polish Criminal Code, and in the Polish Law of 29 July 2005 on Combating Narcotics Addition, that no ruling has been issued with respect to them stating that they have committed such criminal offenses, and that they are not prohibited, under a ruling of a court or another authority or under statutory regulations, from holding any or specific positions, performing any or specific professions, or carrying out any or specific activities related to upbringing, education, rest, medical treatment, psychological counseling, spiritual development, sport, or other hobbies of Minors or related to exercising care over minors.
The representations referred to in sections 5.2.4 and 5.2.6 are made with criminal liability for making a false statement applying. The person making the representation shall include in it the following sentence: “I am aware of criminal liability for making a false statement.” This replaces a warning from a public authority concerning criminal liability for making a false statement.
A person performing the function of a Vocational/Pupil Internship Coordinator or a Vocational Learning Instructor shall make the following representations:
a representation on having read and understood and undertaking to comply with the Standards for the Protection of Minors in force at the Andea Group (Appendix No. 10);
a representation regarding that person’s countries of residence in the last 20 years, if
different than Poland (Appendix No. 1A);
a representation on having no criminal record and a representation that no criminal register is maintained and no information concerning criminal record is issued in a country other than Poland (if, for important reasons, a certificate of no criminal record based on a national criminal register cannot be provided) (Appendix No. 2).
The representations shall be added to the employee’s file, and if no file is maintained,
attached to a civil law agreement.
Refusal to sign any of the documents listed in section 5.4.8 makes it impossible for establishing any legal relationship with that person (execution of an employment contract/cooperation agreement).
6 The Register is available at https://rps.ms.gov.pl/pl-PL/Public#/
7 Additionally, in accordance with Article 120(3a) of the Polish Law of 14 December 2016 on Education, a person providing vocational training is required to submit a certificate of no criminal record.
The Personnel shall know and follow the principles of safe relations between the Personnel
and Minors that are in force at the Employer’s.
Knowledge and acceptance of these principles shall be confirmed by each of the members of the Personnel.
The overriding principle for all of the actions taken by each of the members of the Personnel shall be acting for the good of Minors and in their best interest.
The members of the Personnel shall treat Minors with respect, considering their dignity, needs, and right to privacy.
Any form of violence or abuse towards a Minor is unacceptable.
Entering into any sexual or intimate relations with a Minor is unacceptable.
Recording the image of a Minor (e.g. filming, recording the voice, taking photos) for the private purposes of a member of the Personnel is unacceptable.
Every form of contact with a Minor shall be overt and a result of carrying out official tasks and duties.
It is unacceptable to maintain contacts based on providing financial or material gratifications, on making use of physical advantage, or on a relationship of power over a Minor or a Minor’s dependence, where the intention is the satisfaction or the fulfillment of needs of a member of the Personnel.
It should be ensured that every message, action, or activity addressed to a Minor is appropriate to the situation, the Minor’s level of development, and the Minor’s mental and physical capabilities, as well as safe, justified, and not resulting in unequal treatment of the Minor versus other Minors, including in the form of favoritizing that Minor.
The general principles of safe relations between the members of the Personnel and Minors shall apply to all members of the Personnel and to all persons having contacts with Minors at the Employer’s if such contacts take place in the Workplace.
A detailed description of the principles of safe relations between the Personnel of the Andea Group and Minors constitutes Appendix No. 3.
The Vocational/Pupil Internship Coordinator and the Vocational Learning Instructor shall know and monitor compliance with the principles of safe relations among Minors that are in force at the Employer’s.
The Minors who are completing vocational learning or a pupil internship at the Employer’s
shall know and comply with the principles of safe relations among Minors.
Minors with special educational needs, including Minors with disabilities8
If the Employer carries out vocational learning or pupil internships that involve Minors with special educational needs, including Minors with disabilities and Minors who are not socially adapted or at risk of becoming socially unadapted, the Employer shall adjust these Standards in accordance with the recommendations from the Principal, which shall be based on decisions issued by and evaluations prepared by psychological/pedagogical counseling centers, including specialist ones, and by an occupational medicine physician.
Members of the Personnel shall complete at least basic training in terms of protection of Minors.
The above dissemination activities shall concern in particular:
these Standards for the Protection of Minors (the applicable principles and procedures);
development of skills in terms of identifying risk factors and symptoms of harm being done to Minors;
combating violence and abuse, including by means of intervening in the event of suspecting that harm is being done to a Minor.
It shall be ensured that Minors know that they have the right and option to talk to the person responsible for their protection 9 or to another trusted member of the Personnel who will take actions in order to support them, respecting their privacy, if:
they have a problem, fear or suffer violence or abuse, including a behavior that violates the principles of safe relations from a member of the Personnel, another Minor, a Legal Guardian of a Minor, another close person, or any other person;
they have witnessed an inappropriate, incomprehensible, or unclear behavior, including a behavior specified in the principles of safe relations between a Minor and a member of the Personnel, another Minor, a Legal Guardian of a Minor, another close person, or any person.
8 Article 68(1)(10) of the Polish Law on Education and the Regulation of the Polish Minister of National Education of
9 August 2017 regarding the Conditions for Organizing the Education and Upbringing of and Care Over Children and Youth with Disabilities or Social Adaptation Deficits or At Risk of a Social Adaptation Deficit (Journal of Laws of 2020, item 1309).
9 I.e., the Person Responsible for Receiving Reports in accordance with section 5.7.4.
Obligations of the Employer:
making sure that the Workplace is a safe environment;
appointing a person/persons responsible for:
the Standards for the Protection of Minors;
online safety;
receiving reports;
carrying out interventions;
providing Minors with support;
delegating tasks and responsibilities related to the implementation of the Standards for the Protection of Minors.
The obligations of the Person Responsible for the Standards for the Protection of Minors shall include:
making sure that the Standards for the Protection of Minors are published on the
Employer’s website and available at the Workplace;
preparing the Personnel to apply the Standards for the Protection of Minors;
coordinating educational activities;
cooperating with other persons appointed to implement the Standards for the Protection of Minors;
maintaining a register of the members of the Personnel who have read and understood the Standards for the Protection of Minors prior to commencing work or after an update to the Standards;
monitoring the implementation of the guidelines contained in the Standards for the Protection of Minors, planning evaluations of the Standards that will involve the Employer, the Personnel, and Minors and updating those plans.
The Online Safety Coordinator shall ensure:
guidelines in terms of safe use of the Internet, by means of:
developing internal regulations concerning safe use of ICT networks, including the Internet (the “Principles of Safe Internet Use”), which should be available in a physical form and on the WIKI Andea platform;
presenting the Principles of Safe Internet Use to Minors and the members of the Personnel and informing about all updates of the Principles;
terms of safe use of the Internet on the Employer’s devices, by means of:
determining the scope of blocking access to content that is illegal, harmful, and inappropriate to the age of the user;
installing and regularly updating software that blocks access to content that is illegal, harmful, and inappropriate to the age of Minors, as well as updating the operating systems of devices;
evaluating whether the security software and the software blocking websites, as well as the scope of blocking, are appropriate to the needs of Minors and the changing Internet environment.
The Person Responsible for Receiving Reports shall:
receive reports of occurrence of a risk factor concerning the well-being of a Minor;
receive reports of symptoms of Harming of a Minor or actual Harming of a Minor as well as reports of disclosed or reported incidents or events threatening the well-being of a Minor;
forward reports to the Person Responsible for Interventions (the Employer) and the Principal (if the Minor attends a school) or, if the life or health of the Minor is in direct danger, immediately inform the Police and the Minor’s Legal Guardians (unless they are the source of the danger).
The Person Responsible for Interventions shall:
initiate interventions in accordance with the procedures described below and monitor cooperation with the school;
document reports, verify them, and inform about the conclusions made, including by means of maintaining the Register of Interventions. The Register of Interventions shall be stored in a properly secured location with access provided to the person responsible for maintaining the Register of Interventions and the Members of the Management Board.
The Person Responsible for Providing Support to Minors shall:
cooperate, including with school administration, the Minors’ Legal Guardians, and
other entities in terms of developing plans of supporting Minors,
support Minors by means of:
making sure that Minors are safe, e.g. by isolating them from those who caused harm to them;
ensuring the well-being of Minors and the satisfaction of their current needs (including fundamental physiological needs);
showing kindness and trust to Minors as well as interest in how they feel;
monitor, in cooperation with the administration of the Minor’s school, the support provided to the Minor; if necessary, refer the Minor and/or the Minor’s Legal Guardians to institutions that offer counseling, including psychological counseling, addiction therapy, interventions for perpetrators of violence, support groups, and educational skills workshops (these are e.g. psychological/pedagogical counseling centers, psychological and psychotherapeutic care centers for children and the youth, social welfare centers, and local NGOs).
Threats to the safety of Minors may have various forms and may exist in various channels of contact and communication.
For the purposes of this document, the following types of threats to the safety of Minors are recognized:
suspicion of a criminal offense to the detriment of a Minor (e.g. sexual abuse, other forms of abuse);
suspicion of another form of causing harm that is not a criminal offense (e.g. domestic violence that does not classify as a criminal offense, shouting, humiliation, ridicule, pressure);
suspicion of neglecting a Minor’s necessaries (e.g. those related to nutrition, hygiene,
or health).
For the purposes of this document, intervention procedures have been developed in case of suspected actions to the detriment of a Minor taken by:
adults (members of the Personnel, third parties);
the Minor’s Legal Guardians;
another Minor.
The intervention procedures are formulated in such a way as to support the Personnel in carrying out the legal and social obligation to respond in the event of a suspicion of harm being done to a Minor.
The purpose of an intervention is to stop the harm that is being done to the Minor and make the Minor safe.
In the event of doubt as to how to proceed, the Person Responsible for Interventions may
contact the specialists from the Dajemy Dzieciom Siłę Foundation at 800 100 100.
It is recommended to inform the school attended by the Minor who is completing vocational education or a pupil internship at the Workplace about the intervention.
It should be remembered that in the event of a suspicion of sexual abuse of a Minor below the age of 15, there is a legal obligation to report this to the Police or the Prosecution Office. Failure to do so entails possible imprisonment for up to 3 years. In the case of other criminal offenses, the social obligation to report them rests with everyone.
If the Personnel suspects that a Minor is being harmed or if a Minor or a Minor’s Legal Guardian reports such a situation, a member of the Personnel shall produce an official memo and send it to the Person Responsible for Interventions.
The Person Responsible for Interventions shall immediately receive the report and commence the appropriate actions.
If harm is reported as being done by the Person Responsible for Interventions, the intervention shall be carried out by another Member of the Management Board.
Specialists, including but not limited to psychologists and counselors working at the school attended by the Minor who is completing vocational learning or a pupil internship at the Workplace, may be permitted to participate in the intervention.
An intervention sheet shall be produced with respect to the course of each intervention; the specimen of an intervention sheet constitutes Appendix No. 5 to these Standards. The intervention sheet shall be included in the Register of Interventions maintained at the Workplace.
All of the persons who, in connection with their official duties, learned about the Harming of a Minor or learned related information shall maintain confidentiality, except for the information shared with the authorized institutions as part of an intervention.
If the suspected threat to the safety of a Minor is reported by the Minor’s Legal Guardians and the suspicion does not check out, this should be notified to the Minor’s Legal Guardians in writing.
If it is suspected that a Minor’s life is at risk or a Minor may suffer serious injuries, the relevant services should be immediately informed (the Police, ambulance emergency service, social welfare center) by calling 112 or 998 (emergency ambulance service). The services shall be informed by the member of the Personnel who was first to learn about the threat; this person shall subsequently produce an official memo and send it to the Person Responsible for Interventions, who will be responsible for the further course of the intervention, in accordance with the procedures described in these Standards.
If a suspected case of harming a Minor is reported, the Person Responsible for Interventions shall interview the Minor and the other persons who could have knowledge of the incident, including the Minor’s Legal Guardians.
The Person Responsible for Interventions shall attempt to determine the course of the incident. Conclusions are recorded in the intervention sheet. During the meeting, the Minor’s Legal Guardians are provided with information about the incident, the intervention (if carried out), and the option to take advantage of specialist support, including the support offered by other organizations and services.
The Person Responsible for Interventions shall organize a meeting with the member of the Personnel the report concerns, in order to clarify the situation. Conclusions are recorded in the intervention sheet.
Until the incident has been clarified, the member of the Personnel suspected of Harming a Minor in a form that constitutes a criminal offense under Polish legal regulations shall be asked not to engage in any forms of contact not only with the victim, but also with other Minors.
If a criminal offense is suspected, the Employer shall report this to the Police or the Prosecution Office. In the other cases, the Employer shall take disciplinary actions in accordance with legal regulations and the principles in force at the Workplace.
If a member of the Personnel has Harmed a Minor in a form that does not constitute a criminal offense (e.g. shouting, exclusion, humiliation), the Person Responsible for Interventions should investigate all of the circumstances of the incident, including but not limited to hearing the person suspected of Harming a Minor and other witnesses of the incident. If discrimination or a violation of the dignity of a Minor has taken place, the implementation of the relevant disciplinary procedures, including termination of the contract with the person guilty of Harming, should be considered.
If the Harming of a Minor by the Minor’s Legal Guardian is reported, the Person Responsible for Interventions shall interview the Minor. They should also interview other persons who have or may have knowledge of the incident and the Minor’s personal situation. In this respect, they can cooperate with the personnel of the school attended by the Minor. The Person Responsible for Interventions shall attempt to determine the course of the incident. Conclusions are recorded in the intervention sheet.
If a criminal offense has been perpetrated towards a Minor, the Person Responsible for Interventions shall produce a notification of a possible criminal offense and shall submit it to the relevant unit of the Police or the Prosecution Office.
If a Minor is being harmed by their Legal Guardians or other members of the household in a form that does not constitute a criminal offense:
if the behavior towards the Minor has the features of domestic violence, 10 the Social Welfare Center having jurisdiction over the place of residence of the Minor shall be notified, so that it may initiate the Blue Card procedure;
if the behavior towards the Minor does not have the features of domestic violence, but the Minor suffers neglect or family relations are otherwise incorrect (e.g. the parents are incapable of raising a child), the Person Responsible for Interventions should notify the Principal or other authorized entities that may request the family court having jurisdiction over the place of residence of the child to verify the family’s situation.
The Person Responsible for Interventions shall organize a meeting with an adult family member who is not the person harming the Minor and shall provide them with information about the incident, the intervention (if carried out), and the need/option to take advantage of specialist support, including the support provided by other organizations or services.
If it is suspected that a Minor is being harmed by another Minor staying at the Workplace, the Person Responsible for Interventions shall interview the Minor suspected of harming another Minor as well as the Legal Guardians of that Minor; separately, the Person Responsible for Interventions shall interview the Minor being harmed and their Legal Guardians. Furthermore, the Person Responsible for Interventions shall talk to other persons who have knowledge of the incident. During the interviews, attempts should be made to determine the course of the incident. Conclusions are recorded in the intervention sheet. Separate intervention sheets shall be produced for the Minor doing harm and the Minor being harmed.
It is recommended to get support from the school or the institutions functioning within the
Employer’s area of operations.
During the interviews, it should be confirmed that the Minor suspected of harming another Minor is not being harmed themselves by their Legal Guardians, other adults, or peers. If it turns out that this is the case, an intervention should also be carried out with respect to that Minor.
If the person suspected of Harming is a Minor aged between 13 and 17 and their behavior constitutes a criminal offense, the family court of local jurisdiction or the Police should also be informed by means of the relevant written notification.
If the person suspected of Harming is a Minor aged over 17 and their behavior constitutes a criminal offense, the local unit of the Police or the Prosecution Office should also be informed by means of the relevant written notification.
10 The definition of domestic violence is contained in Article 2(1) of the Polish Law of 29 July 2005 on Combating Domestic Violence (Journal of Laws of 2024, item 424, as amended).
With respect to a Minor being harmed, the Person Responsible for Providing Support to Minors shall develop an individual support plan adjusted to the needs of the Minor and the capabilities of the Employer and, if necessary, based on cooperation with other local entities, as listed in section 4.1.3. For this purpose, the Person Responsible for Providing Support to Minors may contact the personnel of the school attended by the Minor who is completing vocational learning or a pupil internship. The plan should contain elements concerning actions intended to ensure the safety of the Minor, including:
the ways of isolating the Minor from the persons suspected of harming them and enabling the Minor to function freely;
an offer of the support that can be provided, including by other institutions;
referring the Minor to another institution, if necessary. A list of places to which the Legal Guardians of the Minor may be referred if they need help for themselves or their child constitutes Appendix No. 6.
The plan should be developed together with the Minor’s Legal Guardians and discussed with the Minor. If one of the Legal Guardians is the person harming the Minor, the plan shall be developed in cooperation with the non-harming Legal Guardian of the Minor.
A support plan, adjusted to the needs of the Minors and the capabilities of the Employer, shall also be developed with respect to the Minors who witnessed harming.
When providing Minors with access to the Internet, the Employer shall take actions protecting Minors against access to content that could be a threat for their correct development.
The following are considered a threat related to the use of the Internet and electronic media by Minors:
access to illegal content, including content showing sexual abuse of Minors, pornographic content, content that promotes racism and xenophobia, and other illegal content constituting a threat to the safety of Minors;
access to harmful and inappropriate content, including:
content that shows cruelty and bodily injuries;
content that shows drastic scenes, such as death or cruelty to animals;
content that encourages the viewer to take self-destructive actions;
content that encourages violence, crime, radical behaviors (including sects), and extremism;
trash streams;
discriminating content;
pornographic content;
access to harmful and inappropriate online contacts and services, resulting e.g. in peer pressure, cyber violence, and access to commercials not intended for the age of the viewer;
access to harmful and risky behaviors, including participating in online challenges, exerting pressure, and using violence through information and communication technologies.
When providing Minors with access to the Internet via the Employer’s own wi-fi network (or in another manner), the Employer shall take actions intended to block access to content that is illegal, harmful, and inappropriate to the Minors. For this purpose:
the scope of securing and blocking access to content that is illegal, harmful, and inappropriate to Minors shall be determined;
specific software (including e.g. anti-virus software, user activity monitoring tools, etc.) shall be selected;
securing and blocking software shall be installed;
the software referred to in section 7.1.3.3 shall be updated on an ongoing basis.
A prerequisite for a Minor to be allowed to use the Employer’s devices shall be the Minor reading and understanding the Principles of Safe Internet Use. Efforts shall be made to make sure that the process of reading and understanding is effective and corresponds to the needs of Minors.
In the case of content that is illegal, harmful, or inappropriate to age or in the case of an incident having a negative effect for the safety of Minors in connection with using the Internet, the following actions shall be taken:
every report/disclosure of harmful or inappropriate content should be registered, analyzed, and properly documented. The analysis should include a detailed description of the incident, specify the persons involved and/or the actions taken to identify the perpetrator, and materials documenting the incident. This evidence should be secured in a manner that respects the rights of the Minor, including their right to privacy;
evidence should be secured and described (date of receipt, contents of the message, details of the sender: user name, e-mail address, website address). If the evidence gathered suggests a violation of legal regulations, the Police should be notified immediately;
after the incident, regular post-intervention monitoring should be carried out, checking the situation and the needs of the Minors involved in the incident and/or the persons harmed as a result of the incident.
Actions concerning incident participants should be addressed to the persons harmed, the perpetrators, and the witnesses. Some actions may be related exclusively to working with the persons harmed; others will require various educational and/or disciplinary actions to be taken towards the perpetrator. It should be remembered that the actions taken will mainly concern Minors, which means that s Minor’s Legal Guardian will be involved in all of them.
The actions taken by the Employer should be planned, gradual, and adapted to the situation and shall be carried out in the following sequence:
interviewing the witnesses of the incident, with the nature of the event and the role of the interviewee (harmed person/perpetrator/witness) taken into account. Language that shifts the guilt and responsibility to the harmed person should not be used;
notifying the Legal Guardians and the persons involved in the incident and informing them about the actions taken by the Employer, and, if applicable, presenting the support plan developed for the harmed Minor;
depending on the situation, notifying the Police or a court if a criminal offense is suspected;
providing support and psychological/pedagogical care to the participants of the incident; care may also be provided by other institutions.
In order to remove from the Internet materials that are illegal, embarrassing, or hurtful, the Legal Guardians of the Minor should be informed that this is possible in cooperation with Dyżurnet.pl (https://dyzurnet.pl/) or by reporting this content via the relevant form available on the website on which the materials were published.
The Minor should be informed about their right to be forgotten, which follows from the General Data Protection Regulation; in justified cases, this allows for removing specific links from the Google search engine, resulting in these links not being displayed in response to any phrase being entered in the search field.
If materials violating the intimacy and privacy of a Minor are published, it is also possible to use the Stop Non-Consensual Intimate Image Abuse website: https://stopncii.org/, which helps remove from the Internet intimate materials presenting the image of a person who did not agree for these materials to be published.
Once every two years, the Person Responsible for the Standards for the Protection of Minors shall evaluate the Standards in order to adapt them to the current needs and ensure their compliance with the applicable legal regulations.
Conclusions from the evaluation should be documented in writing.
In connection with the conclusions made, the Employer makes decisions with respect to whether the Standards for the Protection of Minors should be amended and publishes the new wording of the Standards.
These Standards, as introduced by the Employer, shall come into effect on the day of their publication.
Entities cooperating with the Employer are required to comply with these Standards if their operations include contacts with Minors.
Appendix No. 1 – Representation on having no criminal record and on undertaking to comply with the fundamental principles of protection of minors
Appendix No. 1A – Representation on countries of residence in the last 20 years
Appendix No. 2 – Representation on having no criminal record and representation concerning a country other than Poland not maintaining a criminal register and not issuing certificates of no criminal record
Appendix No. 3 – Principles of safe relations between Andea personnel and minors
Appendix No. 4 – Principles of implementing the procedure of responding to difficult or aggressive behavior or violence on the part of a Minor
Appendix No. 5 – Intervention sheet
Appendix No. 6 – Where to refer a Legal Guardian looking for support for themselves and the Minor
Appendix No. 7 – Specimen of an intervention letter
Appendix No. 8 – Standards for the Protection of Minors – short version for Minors
Appendix No. 9 – Representation of a Minor and their parents/Legal Guardians on having read and understood the Standards for the Protection of Minors
Appendix No. 10 – Representation on having read and understood and undertaking to comply with the Standards for the Protection of Minors in force at the Andea Group
Appendix No. 11 – Andea Group’s register of interventions