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STANDARDS FOR THE PROTECTION OF MINORS

BioCells Medical Limited Liability Company

Medical Facility:
NEURO POSTĘP CENTER OF REGENERATIVE MEDICINE

Table of Contents:

Chapter 1. General Provisions

Chapter 2. Principles Ensuring Safe Relationships Between Minors and Medical Staff

Chapter 3. Catalog of Prohibited Behaviors

Chapter 4. Principles and Procedure for Intervention in Suspected Abuse or Possession of Information About the Abuse of a Minor, and the Person Responsible for Receiving Reports and Informing Relevant Institutions

Chapter 5. Principles for Updating the Standards and the Competencies of Individuals Responsible for Preparing Staff Members for Their Application

Chapter 6. Principles for Providing Parents or Legal or Actual Guardians and Minors with Access to the Standards for Familiarization and Application

Chapter 7. Principles for Using Electronic Devices with Internet Access and Procedures for Protecting Minors from Harmful Content and Online Threats, and Content Stored in Other Forms

Chapter 8. Principles for Establishing a Support Plan for Minors After Disclosure of Harm

Chapter 9. Principles for Protecting the Image of Minors

Chapter 10. Final Provisions

Child Protection Policy - Regulatory Appendices:

Chapter 1: General Provisions

 1. The Standards for the Protection of Minors at NEURO POSTĘP Center of Regenerative Medicine, located in Warsaw, ul. Klimczaka 8 A lok. 94, 02-797 Warsaw (hereinafter: NEURO POSTĘP) were developed in accordance with the legal obligations imposed by the Act of May 13, 2016, on preventing criminal threats related to sexual offenses and the protection of minors, amended by the Minor Protection Act, also known as the Kamilka Act, which will come into force on February 15, 2024.

 2. Whenever this document mentions:

  1. Abuse of a minor – it refers to the commission of a prohibited act or criminal offense (including indecent acts) to the detriment of a minor by any person, including a staff member, or through endangering the minor's well-being, including neglect.

  2. Minor – refers to a person who has not reached the age of 18.

  3. Management – refers to the manager of the medical entity, their deputies, authorized representatives, and any individuals with decision-making powers in the medical entity, regardless of the title of their role.

  4. Staff – refers to all persons employed, collaborating, or providing services at NEURO POSTĘP, who participate in providing health services to minors or may have contact with them, or are involved in the hiring process, regardless of the profession and the legal basis for providing health services or performing duties.

  5. Standards – refers to these Standards for the Protection of Minors.

  6. Employment – refers to the establishment of cooperation with any person based on an employment contract, appointment, designation, or civil-law agreement (including a contract).

​ 3.  Every member of the staff and the management of the medical entity is obligated to comply with the standards.

 4. For the purpose of preventing the abuse of minors, the staff and management are required to take actions defined in the standards, even if they observe or become aware of abuse by third parties or other minors.

 5. The responsibility for implementing, monitoring compliance with, evaluating the implementation of the standards, and other tasks defined in the standards lies with the manager of the medical entity.

 6. The President of the medical entity delegates the tasks mentioned in section 5 to Mr. Andrew Peskau, the CEO.

 7. Before hiring any individual who will provide health services to minors or participate in providing such services, information from the Sexual Offender Register must be obtained to check whether the individual is listed in the register.

 8. Before hiring an individual who will provide health services to minors or participate in providing them, the individual must be required to submit a current certificate from the National Criminal Register regarding offenses defined in Chapter XIX (crimes against life and health) and XXV (crimes against sexual freedom) of the Penal Code, Art. 189a (human trafficking) and Art. 207 (abuse) of the Penal Code, and the Act of July 29, 2005, on counteracting drug addiction or corresponding criminal offenses under foreign law.

 9. In the case of hiring a foreigner, their verification should be carried out to check whether they appear in the criminal registers of their country of origin or the country where they last resided, concerning the offenses specified in section 8 or corresponding prohibited acts sanctioned by the laws of the respective country. The manager of the medical entity is also authorized to require the foreigner to submit a statement of non-conviction.

 10. Only individuals who are not listed in the Sexual Offender Register and who provide a current certificate from the National Criminal Register, confirming that they have not been convicted of the offenses specified in section 8, can be employed at NEURO POSTĘP.

 11. Every member of the staff must familiarize themselves with the standards. Confirmation of familiarity with the standards is provided by submitting a statement, the form of which is Annex 1 to the standards.

 12. The manager of the medical entity conducts a review of the Sexual Offender Register at least once a year, in December, to determine if a staff member who provides health services to minors or participates in their provision at the medical entity is not listed in the register.

 13. In the case of receiving information about:

  1. Initiation or conduct of criminal proceedings against a staff member for offenses defined in section 8, the manager of the medical entity immediately suspends that staff member from all forms of contact with minors;

  2. Conviction of a staff member for a crime or crimes specified in section 8, the manager of the medical entity immediately terminates their employment contract or removes them from their position.

Chapter 2: Principles Ensuring Safe Relationships Between Minors and Staff

 14. The basic principle in the actions undertaken by the staff and management of NEURO POSTĘP in their interactions with minors is acting in their best interest.

 15. Staff members and management:

  1. Treat minors with respect, maintaining calmness and patience in interactions, and showing understanding for their difficulties, problems, and needs;

  2. Ensure the protection of their patient rights;

  3. Respect their right to care from legal representatives or actual guardians;

  4. Where possible, explain the actions being taken and seek consent for the health services being provided;

  5. Allow minors to express their opinions and ensure their right to be heard.

​ 16.  Every person employed at the medical entity who is aware that a minor has suffered physical, psychological abuse, or sexual exploitation is obligated to exercise particular caution and tact in their interactions with that minor.

 17. If a minor, through their behavior, seeks to establish physical contact with a staff member that may be inappropriate or inadequate, the staff member must take appropriate, firm actions, explaining to the minor, with sensitivity, the need to maintain personal space boundaries.

 18. Consent for examining a minor patient must be obtained from an authorized person according to Polish law, except in emergency situations.

 19. The examination of a minor should be conducted in the presence of their legal representative, actual guardian, or, if not possible, in the presence of a staff member.

 20. During the examination of a minor patient, their privacy should be ensured in a manner appropriate to their age, needs, and expectations.

 21. Staff members pay attention to risk factors and signs of abuse of minors.

Chapter 3: Catalog of Prohibited Behaviors

 22. Any form or type of violence against minors is prohibited (both physical and verbal violence), particularly involving aggressive physical contact, criticism, or offensive or discriminatory behavior.

 23. It is prohibited to touch minors in a way that could be misinterpreted or that goes beyond a legitimate medical need.

 24. It is prohibited to present minors with erotic, pornographic, or violent content.

 25. It is prohibited to mock, demean, or label minors.

 26. Physical contact with a minor must never be covert or hidden, must not involve any form of gratification, and must not arise from a relationship of power or authority.

 27. Staff members may not have direct contact with a minor without the presence of their legal representative.

 28. Staff members may not engage with a minor in any form other than for providing health services, especially by inviting or accepting invitations from minors on social media, messaging platforms, or through other private means of contact.

Chapter 4: Principles and Procedure for Intervention in Suspected Abuse of Minors and the Person Responsible for Receiving Reports and Informing Relevant Institutions

29. In the case of observing or receiving information about:

  1. A situation of violence or exploitation of a minor – every staff member or member of the management is obligated to immediately react to stop the prohibited behavior and ensure the protection of the minor;

  2. Behavior that raises suspicion of violence or exploitation of a minor – every staff member or member of the management is obligated to report it to the manager of the medical entity;

  3. Violation of the standards – every staff member or member of the management is obligated to promptly report the suspicion of violations to the manager of the medical entity.

 30. Suspicion of a violation of the standards, particularly involving the abuse of minors, can be reported to Mr. Andrew Peskau or via email at: kontakt@neuropostep.pl

 31. The manager of the medical entity seeks to promptly clarify the matter when suspicion of the abuse of a minor by a staff member is reported, taking all necessary actions. The actions taken are documented by the manager.

 32. In the case of suspicion of abuse of a minor by a staff member, the staff member is immediately removed from all forms of contact with minors until the matter is clarified.

 33. In the case of observing that the legal representative of a minor neglects their psychological or physical needs, or that the family is failing in its upbringing role, using violence against the minor or permitting its use, or otherwise harming the minor and unable to cope, appropriate actions must be taken in response to the situation.

 34. In the situation described in standard 36, in the case of:

  1. Poverty – a conversation can be held with the legal representative of the minor to inform them about support options, especially social assistance centers;

  2. Neglect – the possibility of psychological support can be informed about, particularly via helplines, counseling centers, and specialists available in the respective county;

  3. Violence – the Blue Card procedure can be initiated.

 35. If it becomes clear from a conversation with the legal representative that they are not interested in assisting the minor, ignoring the event or the minor’s psychological or physical condition, or otherwise not supporting the minor who has experienced abuse, the manager of the medical entity must prepare a request for an inspection of the family’s situation and send it to the appropriate family court. A note will be made from the request.

 36. In the case of suspicion that the health or life of the minor is in danger, or if there is a reasonable suspicion of a crime committed against the minor, the manager of the medical entity must prepare a report on the possibility of a crime being committed and forward it to the local police or prosecutor’s office. A note will be made from the report.

 37. In the area where health services are provided, in a space accessible to patients, information about national helplines for victims of crimes and domestic violence will be posted:

  1. National helpline for crime victims: +48 222 309 900;

  2. National Emergency Service for Victims of Domestic Violence "Blue Line" 800 120 002;

  3. Child and Youth Helpline 116 111.

Chapter 5: Principles for Updating the Standards and the Scope of Competencies of Individuals Responsible for Preparing Staff Members for Their Application

 38. The manager of the medical entity conducts a review of the standards at least once every two years to ensure they are adapted to current needs and in compliance with applicable regulations. The conclusions from the evaluation should be documented.

 39. Staff members, minors, or their legal representatives may provide their comments on the standards to the manager of the medical entity.

 40. The manager of the medical entity may check the staff's knowledge of the standards and organize training on the standards.

Chapter 6: Principles for Providing Parents or Legal or Actual Guardians and Minors with Access to the Standards for Familiarization and Application

 41. The standards are a publicly accessible document. The standards are available:

  1. In the office of the medical entity;

  2. At the reception of the medical entity;

  3. On the website of the medical entity at: www.biotechdent.com.

 42. Every minor or legal representative of a minor can receive a copy of the standards available at the reception for review.

 43. A shortened version of the standards, containing information important for minors, has been prepared based on the standards. The shortened version of the standards is Annex 3.

Chapter 7: Principles for Using Electronic Devices with Internet Access and Procedures for Protecting Minors from Harmful Content and Online Threats, and Content Stored in Other Forms

44. The medical entity provides access to the internet.

45. Internet access is secured with a password and configured to prevent access to the following types of websites:

  1. Pornographic or erotic content;

  2. Images depicting violence or cruelty towards other people or animals;

  3. Gambling sites;

  4. Unmodified chat rooms.

Chapter 8: Principles for Establishing a Support Plan for Minors After Disclosure of Harm

46. After the abuse of a minor is disclosed, the manager of the medical entity establishes a support plan for the minor in collaboration with their legal representative, unless the representative is the one committing the abuse.

47. If possible, after establishing the support plan, the manager of the medical entity listens to the minor’s opinion and takes it into account.

Chapter 9: Principles for Protecting the Image of Minors

 48. The image of a minor is protected.

 49. The publication of the image of a minor captured in any form (e.g., photography, audio-video recording) requires written consent from the minor's legal representative.

 50. If the image of a minor is merely a detail of a larger whole, such as a gathering, landscape, or public event, consent from the legal representative for recording the minor's image is not required.

 51. The image of a minor captured by surveillance cameras used for recording sound or images for security purposes within the medical entity is not subject to publication and does not require the legal representative's consent for recording the image. The use of materials captured in this manner is limited exclusively to the original purpose for which they were recorded.

Chapter 10: Final Provisions

 52. The standards for individuals employed at NEURO POSTĘP have the force of internal regulations, which they are obligated to follow.

 53. The standards come into effect on the day of their announcement. The announcement of the standards is made by publishing them in the manner specified in standard 41.

 54. The manager of the medical entity is authorized to make changes to the standards. The amended standards come into effect on the day of their announcement in the manner specified in standard 41.

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