PURPOSE OF THE CHILD PROTECTION POLICY

1. Provide the employees of Arena Hospitality Group d.d. (and its business partners that may get in contact with children in the performance of their contractual duties, such as cleaning services and tenants) with the guidelines for a more efficient and safer behaviour and attitude towards children;
2. Express commitment of Arena Hospitality Group d.d. to adhere, in its operations, to the provisions of the Convention on the Rights of the Child (an international document outlining universal standards of duties of adults towards children as well as the duties of many social factors relating to child protection, where the term “child” applies to all persons under the age of 18);
3. Preventive impact on the employees’ behaviour and attitude towards the protection of children they interact with within the scope of business activities of Arena Hospitality Group d.d.;
4. Prescribe the procedure for reporting illegal behaviour towards a child.

VALUES AND PRINCIPLES PROTECTED BY THIS POLICY

• Child’s health and safety
• Child’s welfare and development
• Unacceptability of illegal and abusive behaviour toward children
• Duty of the adults (employees of Arena Hospitality Group d.d.) to safeguard children in their working environment
• Business partners of Arena Hospitality Group d.d. that might get in contact with children in the performance of their contractual duties are obliged to adhere to the standards for the protection of children under this policy
• Respect of child’s culture, religion and ethnic origin

CODE OF CONDUCT

Arena Hospitality Group d.d. staff and its business partners that may get in contact with children in the performance of their contractual duties must not:

• hit or otherwise physically hurt or abuse children;
• behave physically in a manner which is inappropriate or sexually provocative;
• engage in any unnecessary physical contact with children and interact too intimately with children;
• have sexual intercourse or an equivalent sexual activity with a child or make a child have sexual intercourse or an equivalent sexual activity with a third party or with himself/herself;
• develop relationships with children that could in any way be deemed exploitative or abusive;
• act in any way that may be abusive or place a child at risk of abuse;
• use language, make suggestions or offer advice to children which is inappropriate, offensive or demeaning in any way whatsoever;
• condone, or participate in, the behaviour of children which is illegal, unsafe, or abusive;
• humiliate, belittle or degrade children or otherwise perpetrate any form of emotional abuse;
• discriminate against, show different treatment or favour particular children to the exclusion of others.

Arena Hospitality Group d.d. staff and its business partners that may get in contact with children in the performance of their contractual duties are obliged to avoid any action or form of behaviour that may be interpreted as potential abuse and, in the performance of their work rights and duties, they must:

• Be aware of situations which may present risks related to child protection issues;
• Plan and organize the work and the workplace so as to minimize risks related to child protection issues;
• Avoid spending time alone with children, beyond the scope of business activities;
• Make sure that inappropriate behaviour toward children is punished.

In order to ensure the observance of the above, Arena Hospitality Group d.d. as employer and business partner undertakes to:

• Ensure that its employees and business partners (that may get in contact with children in the performance of their contractual duties) get familiar with the contents of the Child Protection Policy;
• By signing the Declaration Form, Arena Hospitality Group d.d. employees will undertake to observe the Code of Conduct outlined in the Child Protection Policy;
• By signing the Declaration Form, all business partners (that may get in contact with children in the performance of their contractual duties) will undertake to observe the Code of Conduct outlined in the Child Protection Policy;
• In every hotel/camping site/tourist resort (or in the manager’s office of a particular profit centre or department), there is a copy of the Child Protection Policy available for inspection;
• The Child Protection Policy Memorandum and the Declaration Form to be signed by all employees and business partners (that may get in contact with children in the performance of their contractual duties) includes the contact details of the Management of Arena Hospitality Group d.d. (Legal Department) that any violation of children’s rights in the work environment should be reported to.

Arena Hospitality Group d.d. will take all necessary measures to protect the rights of children from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, by superiors, business associates, and persons with whom the child/minor comes in contact on a full-time basis. Arena Hospitality Group d.d. staff and its business partners (that may get in contact with children in the performance of their contractual duties) are obligated to report to the Management of Arena Hospitality Group d.d. (Legal Department) any and all forms of child harassment in order to punish every forbidden behaviour (pursuant to the decision of the Management of Arena Hospitality Group d.d.) and, if appropriate, to request the protection of children’s rights through legal channels, in accordance with the applicable criminal provisions.

The report must be filed:

1) in writing – to the address: Arena Hospitality Group d.d. Pula, Smareglina 3, 52 100 Pula, Croatia, or via email: [email protected] (specifying: for Legal Department/Child Protection Policy); or 2) orally, by calling the phone number 052/217-034 (Management of Arena Hospitality Group d.d.) or 052/ 223-811 (Operator/Legal Department). The Management of Arena Hospitality Group d.d. (Legal Department) is obligated to review the report at latest within 1 day from the date of filing the report and to take all necessary measures to prevent the occurrence of further harassment. Using the same methods, people can request interpretation and information relating to the Child Protection Policy. Should they become aware of a violation of children’s rights, Arena Hospitality Group d.d. staff and its business partners (that may get in contact with children in the performance of their contractual duties) can address the following institutions:

• Make a report (in writing, by phone, orally) to the competent Social Services Department (contact details of the Social Services Department Pula: Address: Sergijevaca 2, Pula, 52100 HR, email: [email protected], phone: +385 52 214 537, Fax: +385 52 212 458)
• File a report with the competent police department (by calling the police emergency number 192),
• Depending on the type and severity of the offence (Criminal Code, OG 125/11, 144/12, 56/15, 61/15, 101/17, 118/18) file criminal charges with the nearest Municipal or County State's Attorney's Office (address: Kranjčevićeva 8, Pula, phone: 052 222 655, fax: 052 222 691, email address: [email protected], or County State's Attorney's Office in Pula – Pola, address: Kranjčevićeva 8, Pula, phone: 052 300 070, fax: 052 212 584, 052 300 085, email address: [email protected]). Should the abuse be filed with the Social Services Department or the police, they will forward the report to the State's Attorney's Office, along with the information they have gathered relating to the report. Should the report of child abuse be submitted to a non-competent State's Attorney's Office, the report will be handed over to the competent State's Attorney's Office for further proceedings.
• File a report with the Children’s Ombudsman in case of violation of an individual child’s right or general phenomena that are threatening children’s rights and interests. Reports may be filed orally, by phone or in person, and in writing: via mail, to the address Children’s Ombudsman, Teslina 10, 10000 Zagreb, by fax to the number + 385 1 4921 277, or email [email protected], to the special email address just for children [email protected] 

These institutions (i.e. their phone numbers) can be found in the phone book, and information about said institutions is available on the Brave Phone (number 0800 0800).

There are several NGOs dealing with the protection of children’s rights that operate in the territory of the Region of Istria:

• NGO „Naša djeca“ Pula (“Our Children” Pula), (Open phone line for assistance in exercising children’s rights in Istria Region, address: 52100 Pula, phone: 0800 334 400. The open phone line is toll free and available every business day from 5 pm to 7 pm), and
• NGO “Sigurna kuća Istra” (“Safe House Istria”) (Address: Koparska 58, 52100 Pula phone: 052/500-148, email: [email protected]. The phone line is available every business day from 8 am to 2 pm, and Mondays and Fridays from 8 am to 2 pm and from 5 pm to 7 pm. Coming to the NGO, after taking an appointment over the phone, it is possible to get help from a psychologist, a lawyer and a social service worker).

Should guests of Arena Hospitality Group d.d. facilities notice any form of child harassment and turn to the staff of the Arena Hospitality Group d.d. facility they are staying at with the intention to report forbidden behaviour towards a child, the management personnel of the respective facility will file a report on behalf of the guest based on his/her written report on the event or inform the guest about the procedure of filing a report of forbidden behaviour towards a child as described in this Child Protection Policy.

PROTECTION OF MINORS ON THE OCCASION OF THEIR EMPLOYMENT AT ARENA HOSPITALITY GROUP D.D.

The Labour Act, OG 93/14, 127/17 (hereinafter referred to as: Labour Act) provides minors with the right to work, but it also contains certain provisions that govern the manner of such work in line with many conventions on fundamental human rights (Council Directive 94/33 EU of 22 June 1994 on the Protection of Young People at Work). The protection of minors provided for by the Labour Act is amended by many bylaws providing for additional legal protection of this particularly threatened age group. Hence, the possibility for minors to work is exceptionally allowed, provided that their rights, interests, mental and physical development, as well as mental and moral integrity are protected.

Execution of employment contracts

Pursuant to Section 19 of the Labour Act, persons younger than fifteen and older than fifteen, but younger than eighteen, who attend the compulsory primary education, may not be employed. However, the Act provides for exceptions in case of minors that have turned fifteen and the ones older than fifteen who do not attend the compulsory primary education (Section 20 of the Labour Act). If the legal representative (typically a parent) gives permission to such minor to enter into an employment contract, the minor has the legal capacity to enter into the employment contract and to terminate it as well as to exercise his/her rights and duties under or arising out of such contract. The legal representative is allowed to revoke or limit the consent at any time, and to terminate the employment on behalf of the minor. A special situation arises if the legal representatives are in conflict or if there is a conflict between several representatives and the minor. In this case, the grant of the consent will be decided by the body responsible for social services matters, while taking into account the interests of the minor. Exceptionally, in case of the existence of guardianship over the minor’s person, the consent is given by the guardian based on prior approval of the body responsible for social services matters. In any of the above cases, the consent for the execution of an employment contract must be given in writing. By all means, an employer cannot employ a minor who does not have the consent of his/her legal representative as required by law, or the approval of the body responsible for social services matters.

The Bylaw on the performance of activities related to job placement (OG28/19) governs the terms and conditions and the method of carrying out activities related to employment mediation, career counselling, workforce education and training with the aim of enhancing employability, when these activities are carried out by legal and natural persons outside the Croatian Employment Service.

Consequently, mediation of secondary education institutions in employment of full-time students is foreseen as an additional instrument for the protection of minors. Secondary education institutions may carry out mediation activities for occasional work of their full-time students in the country and, exceptionally, for full-time students from other secondary education institutions having seat in the same region, based on a written agreement that they are obligated to submit to the ministry in charge of labour. Secondary education institutions must have a permission of the ministry in charge of labour for carrying out mediation activities for occasional work of their full-time students i.e. they must be registered in the relevant records of the ministry in charge of labour. In the event of mediation carried out by secondary education institutions, Arena Hospitality Group d.d. (as the employer - principal) executes with full-time students of secondary education institutions (with co-signature of the legal representative or guardian) a Contract on occasional work of full-time student.

The contract must include the number under which the secondary education institution is registered in the records of the ministry in charge of labour, name and surname of the student, student’s date and place of birth, student's personal identification number, membership card number, full name and address of the employer - principal, data on the type of tasks, the number of work hours, the hourly rate, and the amount of earnings.

• Full-time work for a minor full-time student must not be longer than seven hours a day and 35 hours a week.
• Exceptionally, full-time work for a minor full-time student who has turned 15 can be eight hours a day and 40 hours a week.
• A minor full-time student who works more than 4 hours and 30 minutes a day is entitled to a break (rest break) of at least 30 minutes.
• Between two consecutive working days, a minor full-time student is entitled to a rest period (daily rest) of at least 14 consecutive hours.
• A minor full-time student is entitled to a weekly rest of at least 48 uninterrupted hours.
• Work of a minor full-time student is forbidden in the period between 8 pm and 6 am.
• The contract is executed in three identical copies.

Prohibition for minors to perform certain types of jobs

Pursuant to Section 21 of the Labour Code, a minor cannot be employed on jobs that threaten his/her safety, health, morals, or development. The Ministry of Labour and Pension System issued a Bylaw on prohibited jobs for minors (OG 89/15, 94/16), according to which minors must be protected from any special hazard to their safety, health and development, that is a consequence of their lack of experience, unawareness of existing or potential hazards, or the fact that they are still not entirely mentally and physically mature. Jobs that will probably be considered especially hazardous in the light of the above include: harmful exposure to physical, biological or chemical agents, and jobs, procedures and work that are specified in the Appendix to the Bylaw. In order to protect their health and development, minors must not be employed on jobs:                                 

• identified, according to the work safety regulations, as jobs with special working conditions;                    
• identified, according to special regulations, as particularly demanding and harmful to health, which are performed in reduced working hours, or the time of their performance is accounted for retirement insurance with extended duration.

Furthermore, a minor must not be employed on jobs that are objectively above his/her physical or mental abilities; that include harmful exposure to agents which are toxic or carcinogenic, cause heritable genetic damage or are harmful to an unborn baby, or have a long-lasting impact on human health; that include harmful exposure to radiation; that include risk of accidents that are expectedly not to be recognized or avoided by the minor due to his/her insufficient attention to safety, or his/her lack of experience or training; that include life danger due to exposure to extreme cold or heat; that include noise and vibration hazards which are harmful to health; production of and handling devices, pyrotechnic devices, and other items that contain explosives; that include working with the machinery for production, storage or use of compressed, liquefied or dissolved gases; that include working with barrels, tanks, storage tanks or bottles which contain chemical agents which are toxic or carcinogenic; that include risk of building collapse; that include risk of high-voltage electricity; whose rhythm is determined by machines and includes performance-based payments. As an exception from the above, a minor may be employed on jobs with special working conditions if he/she has completed specialized secondary education for these jobs, provided that he/she also meets other prescribed requirements and that he/she has been issued a medical fitness certificate required for performing these jobs in a manner provided for by a special bylaw regulation that governs the determination of medical fitness in case of minors. Arena Hospitality Group d.d. will not employ a minor, without prior determination of medical fitness, for jobs that can be performed by a minor only after such determination. In circumstances when a minor may work on jobs with special working conditions, he/she will carry out such job duties exclusively under supervision of an authorized person to be appointed by Arena Hospitality Group d.d. as the employer.

Supervision of minor’s work on specific jobs

Should a minor, his/her parent i.e. guardian, the works council or the trade union suspect that the job duties performed by the minor threaten his/her safety, health, morals, or development, they may request from the employer an examination of the minor by a licensed doctor who will evaluate in his/her findings and opinion whether the job duties performed by the minor are hazardous to his/her safety, health, morals, or development. Costs for such medical examination and the findings and opinion as under this article will be borne by Arena Hospitality Group d.d. Should it result from the findings and opinion that the job duties performed by the minor threaten his/her safety, health, morals, or development, Arena Hospitality Group d.d. is obligated to offer to the minor the execution of an employment contract for performance of other appropriate jobs and, in case there are no such jobs, it may dismiss him/her in the manner and under the conditions provided for by the Labour Act.

Furthermore, for the purpose of protection of health, safety and development, the Bylaw on jobs that may be performed by minors and on activities in which they may participate (OG 62/10, OG 93/14) specifies the jobs that can be performed by a minor only after prior determination of medical fitness for performing such jobs, and the mode of determination of medical fitness, intervals for redetermination of medical fitness, the content and the method of issuance of the medical fitness certificate, and other issues of relevance for the determination of medical fitness of a minor, as well as the activities in which, prior approval of the labour inspector, a person under 15 years of age, or a person that has turned 15 and is older than fifteen but younger than eighteen, who attends the compulsory primary education, may participate for compensation.

Arena Hospitality Group d.d. may be held liable for any breach of the provisions under the Labour Act that refer to minors, and such violation is considered a major violation punishable by fine.

Arena Hospitality Group d.d. Company Level Agreement

With the Company Level Agreement and its annexes, Arena Hospitality Group d.d. and STUH (Tourism and Services Trade Union of Croatia) have agreed on the protection of minors’ work-related rights and duties by using the prescribing possibilities provided by Croatian labour legislation and the Council Directive 94/33 EU of 22 June 1994 on the Protection of Young People at Work (provisions on minor’s work, work hours, work at night, right to rest breaks, weekly rest, annual leave, remuneration for students on compulsory practical full-time work training, etc.).

AMENDMENTS TO THE CHILD PROTECTION POLICY

Arena Hospitality Group d.d. reserves the right to modify the Child Protection Policy at any time, in full or any of its parts, depending on any regulation amendments or business requirements.