POLICIES AND PROCEDURES FOR THE PROTECTION OF MINORS IN
JOITIN SPÓŁKA AKCYJNA

INTRODUCTION

The Standards for the Protection of Minors implement the legal obligation incumbent on JOITIN S.A. /hereinafter also: JOITIN/. They are specific written rules, policies and practices that ensure that minors are safe and do not suffer harm from JOITIN staff and peers. The most important principle of all actions taken by staff at JOITIN is to act for your good and in your best interest. JOITIN staff, in pursuing the goals of the introduced Standards for the Protection of Minors, act only within the framework of applicable law.

Chapter I
Explanation of terms

1. Minor is any person under the age of 18.
2. Staff is any person who is an employee of JOITIN.
3. Coordinator is the person designated by JOITIN to coordinate all activities related to the protection of minors.
4. Abuse of a minor is defined as the intentional or unintentional act of an adult or other minor that results in the violation of your rights, freedom or adversely affects your physical or mental development.

Chapter II
Protection of minors in JOITIN

1. JOITIN has and applies the document “Standards for the Protection of Minors”, which is available at the premises for review by staff and minors.
2. The Standards for the Protection of Minors document stipulates, among other things:
   • rules for the safe recruitment of personnel to work at JOITIN to ensure that the person who comes into contact with you will ensure your safety;
   • procedures for reporting suspicions and intervening, which outline step-by-step what action to take if you are being harmed or your safety is threatened by strangers, family members, JOITIN staff and peers;
   • rules for safe relations between JOITIN staff and minors, specifying what behaviors are not allowed when interacting with minors.
3. JOITIN staff, including volunteers and trainees, are aware of the contents of the Standards for the Protection of Minors from Harm document and are required to apply it.

Chapter III
Designated employees

1. There is a designated coordinator and deputy coordinator in JOITIN responsible for monitoring the implementation of the Standards for the Protection of Minors. Their role and tasks are clearly defined.
2. The persons to whom you can report in case of abuse or violation of standards are:
   • all employees who are required to pass on the reported situation,
   • coordinator – Paweł Janoszek
   • deputy coordinator – Paweł Janoszek

Chapter IV
Recognizing and responding to risk factors for abuse of minors

1. JOITIN staff, as part of their duties, pay attention when you or another minor is harmed.
2. There are the following basic forms of harm:
   • physical violence – an act or omission as a result of which you or a peer suffers actual physical harm or is potentially threatened with physical harm. The harm is the result of an act or omission on the part of a parent, guardian, a person responsible for the minor, having authority over him or her, or one he or she trusts. We speak of physical violence both on a one-time and repeated basis;
   • psychological violence – a chronic, non-physical, harmful interaction between you or your peer and a person responsible for you or someone you trust. As with physical violence, it includes both actions and inactions. Some of the manifestations of psychological violence include:
     • emotional unavailability,
     • emotional neglect, a relationship based on hostility, blaming, denigration, rejection, developmentally inappropriate or inconsistent interactions, failure to recognize or acknowledge individuality, failure to recognize or acknowledge psychological boundaries, inadequate socialization, demoralization,
     • i. sexual violence (sexual abuse) – involving you or your peer by an adult or other minor in sexual activity. This includes situations where there is no physical contact (e.g. exhibitionism, verbal harassment – e.g. having conversations with sexual content inappropriate for your age, making sexual comments about your appearance and behavior, encouraging contact with pornographic content, grooming – strategies of non-sexual grooming of a minor with the intention of having sexual contact in the future) and when such contact does occur (situations such as touching, forcing to touch the perpetrator’s body, sexual intercourse). Any sexual activity undertaken with a minor before the age of 15 is a crime. In the case of minors, we speak of sexual abuse when there is a relationship of power, care or dependence between the abuser (an adult, another minor) and the abused (a minor) due to age or stage of development.
3. You may experience violence from other peers, parents or guardians, third parties (people with whom you interact), or JOITIN staff.
4. The rules for safe relations of JOITIN staff with you and your peers are included in Appendix 3 of the Standards for the Protection of Minors.

Chapter IV
Procedures for intervention in cases of abuse of minors

1. If you experience any form of abuse by adults or other peers, notify a staff member or the coordinator/deputy.
2. An appropriate procedure will be launched for the situation you report, tailored to the problem you are facing.
3. Don’t be afraid to indicate in what form you are experiencing abuse or the perpetrator of these behaviors. JOITIN staff have been trained and know how to handle such a situation.
4. JOITIN staff have a duty to keep confidential any report of harm to you or your peer
5. Remember that as the person being harmed, you are not the one to blame for the situation and you have the right to ask for help.
6. if the report would involve a JOITIN staff member report it to someone other than the staff member who engaged in reprehensible behavior toward you.

Chapter V
Principles of protection of the image of minors

1. JOITIN recognizing your right to privacy and protection of personal property ensures the highest standards of protection of your personal data and your image in accordance with applicable laws.
2. Consent for publication of your image may be given in writing by your parents or legal guardians.

Chapter VI
Monitoring the application of the Standards

Once every two years, an analysis of the implementation of the Standards for the Protection of Minors is carried out and, if necessary, JOITIN makes the necessary changes to the Standards and announces the new wording of the Standards to staff and minors.

Chapter IX
Final provisions

1. The standards introduced by the employer shall enter into force on 1.04.2025 r.
2. Announcement shall be made in a manner that is accessible to staff and minors, in particular, by posting in the notice area and by posting on the website.
3. Entities cooperating with JOITIN, in case their activities involve contact with minors, shall be obliged to comply with these Standards.