Minor Protection Policy (“POM”)

Elab Education Laboratory spółka z ograniczoną odpowiedzialnością spółka komandytowa, with its registered office in Warsaw, hereinafter referred to as “ELAB”, in the course of its activities always puts the welfare of the Applicants first, cares for both their dignity and their rights and, in this spirit, takes measures to protect them.

Every ELAB employee and subcontractor treats all Applicants, especially minor Applicants, with respect and considers their needs and responds to risks.

It is absolutely unacceptable for ELAB, our employees and subcontractors to use violence in any form against children.
 
This Policy sets out the most important rules and assumptions related to ensuring the maximum level of safety of minors who are ELAB Applicants, as well as guaranteeing the highest level of protection of minors for whom the services provided by ELAB are carried out, both by the staff of the ELAB office in Warsaw and all persons cooperating with ELAB, in any capacity, including tutors, mentors or subcontractors of other educational support services.

  1. Rules to ensure a safe relationship between the minor and ELAB’s employees and subcontractors, in particular prohibited behaviour towards minors:
    1. ELAB’s employees and subcontractors in direct contact with minors should perform their tasks in a way that protects the rights of third parties, in particular the rights of children, with respect and in a polite and cultured manner;
    2. It is unacceptable to use any form of verbal, psychological and especially physical violence against minors;
    3. ELAB’s employees and subcontractors referred to in para. 1.1 are required to refrain from any behaviour that might violate a minor’s personal space, cause him or her to feel threatened, uncomfortable or afraid;
    4. ELAB’s employees and subcontractors referred to in para. 1.1 should be alert to disturbing behaviours of minors that may indicate abuse and should attempt to contact the minor if they suspect such abuse. If a minor attempts to make contact with an ELAB’s employee or subcontractor, such employee or subcontractor should listen to the minor and, as far as possible, obtain the fullest possible information about the minor’s situation.
  2. Rules and procedure for intervening in situations of suspected abuse or having information about abuse of a minor, as well as for reporting suspected offences against a minor and notifying the guardianship court:
    1. In a situation of suspected abuse or having information about abuse of a minor, an ELAB’s employee or subcontractor is required to immediately inform his or her immediate supervisor or the person designated to supervise his or her work, verbally, as well as in writing, by submitting an appropriate memo;
    2. The communication of the information referred to in para. 2.1 should be made on the same day that the ELAB’s employee or subcontractor becomes aware of the suspicion or information. If an ELAB’s employee or subcontractor is not present at ELAB’s premises on the day in question, he or she is obliged to pass on the information by telephone or e-mail to a designated person;
    3. Once the information referred to in para. 2.1 has been passed to the ELAB subcontractor’s line manager or supervisor, that person should first determine which entities and institutions should be informed of the suspected abuse of a minor, inform them and then complete an Incident Report Form;
    4. If, as a result of the findings referred to in para. 2.3, it is determined that it is reasonable to make an application to the family court as referred to in Article 572 of the Act – Code of Civil Procedure or to file a notice of suspicion of an offence, the ELAB Operations Director himself or herself, or a person designated by him or her, shall immediately refer such an application to the competent authorities;
    5. All ELAB’s employees and subcontractors, as well as other persons who, in connection with the performance of their duties, have taken information about child abuse or information related to it, are obliged to keep this information confidential, excluding information provided to authorised institutions as part of intervention activities.
  3. Principles for reviewing and updating the Minor Protection Policy:
    1. This Policy is reviewed every two years for compliance with applicable legislation and to assess its substantive suitability;
    2. The verification referred to in para. 3.1 shall be carried out by the ELAB Operations Director or the person designated by him or her;
    3. As a result of the verification referred to in para. 3.2, an evaluation report is drawn up indicating possible suggestions and directions for updating the Minor Protection Policy.
  4. The scope of authority of the person responsible for preparing ELAB’s employees and subcontractors to apply the Minor Protection Policy, the rules for preparing these employees to apply the Minor Protection Policy and how to document this activity:
    1. The person responsible for preparing ELAB’s employees and subcontractors for the application of the Minor Protection Policy is designated by the ELAB Operations Director;
    2. ELAB may subcontract the task referred to in para. 4.1 to an external body that gives the assurance of sound performance of the tasks in question and has the appropriate competence and experience;
    3. As part of the preparation of ELAB’s employees and subcontractors for the use of the Minor Protection Policy, training in the appropriate scope shall be provided;
    4. Each of ELAB’s employees and subcontractors declares that they have read ELAB Minor Protection Policy;
    5. Attendance at the training course referred to in para. 4.3. shall be confirmed by a named attendance list.
  5. The rules and manner in which the Minor Protection Policy is made available to parents, legal or actual guardians and minors:
    1. This Policy is subject to publication on the ELAB website and is also displayed in a prominent place at the ELAB premises in Warsaw.
  6. Method of documenting and rules for storing the disclosed or reported incidents or events endangering the welfare of a minor:
    1. An internal register of disclosed or reported incidents or events endangering the welfare of a minor shall be established;
    2. The register referred to in para. 6.1 shall be kept at the ELAB premises in paper form and on ELAB disks in electronic form;
    3. The ELAB Operations Director shall appoint a person responsible for maintaining and completing the register referred to in para. 6.1.
  7. Principles for establishing a plan to support a minor after disclosure of abuse;
    1. If abuse of a minor is disclosed, the responsible persons shall prepare a plan to support the minor, subject to para. 7.2;
    2. If a “Blue Cards” procedure is being carried out, in which the minor is recognised as a person experiencing violence, the support plan shall not be established;
    3. The preparation and implementation of the support plan is the responsibility of the employee’s immediate supervisor or the supervisor of the ELAB’s subcontractor who becomes aware of a particular case of abuse of a minor.
  8. The Minor Protection Policy shall come into force on 1 December 2024 and shall be published on the ELAB website and in a prominent place at the ELAB premises in Warsaw.
  9. Any amendments to the Minor Protection Policy must be made in writing and shall be published in the consolidated text and with the indicated effective date in the manner referred to in para. 1.