Стандарти за защита на непълнолетните в Fluentbe

In effect from: 1 January 2026 Updated: 31 August 2026

1. Purpose and scope of the document

1. Ensuring the safety of minors participating in online classes conducted by Fluentbe.
2. Establishing rules and procedures aimed at preventing harm to minors.
3. This document applies to all employees, teachers, associates, partners, and other persons acting on
4. behalf of Fluentbe (hereinafter collectively referred to as: Personnel, unless the context of this document
5. indicates otherwise) who have contact with minors as part of online classes.
6. This document (the Child Safeguarding Standards) has been developed based on the Act of 13 May 2016 on Counteracting the Threat of Sexual Offences and the Protection of Minors, in particular Articles 22b and 22c thereof.

2. Definitions of key terms

Fluentbe or the Company – Fluentbe Spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw (00-895), at ul. Biała 4, unit 81, entered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw, XIII Commercial Division, under KRS number 0000562340, with share capital of PLN 99,550, holding NIP (Tax Identification Number): 527-27-38-544.

Minor – a person who has not yet reached the age of 18.

Guardian – a parent or legal representative of the minor.

Harm to a minor – any act or omission that endangers the physical, psychological, or sexual safety of a minor, including Online Abuse.

Online Abuse – includes, among others, grooming, cyberbullying, sexting, unauthorised recording, or the unauthorised sharing of materials.

Contact with a minor – any form of relationship or interaction (the decisive factor being the real possibility of contact) in which an adult:

1. has a direct or indirect influence on the minor,
2. may find themselves alone with the minor or in a situation requiring trust,
3. performs activities that create the possibility of infringing upon the wellbeing of the minor, even if such activities are brief or incidental.

3. Safety rules and principles for working with minors in the online environment

1. All classes are conducted via official platforms and tools provided and made available by Fluentbe.
2. Any contact with a minor outside official communication channels (e.g. via private social media profiles, private telephone numbers, or private email addresses) is prohibited.
3. Personnel are required to use cameras during online classes and to communicate in a professional manner appropriate to the age of the minor.
4. Private conversations and online meetings, or any meetings without the knowledge and presence of the Guardian, are not permitted.
5. 1:1 classes must be conducted in a transparent manner (e.g. allowing the Guardian the possibility to observe the class).
6. Personnel must ensure secure privacy settings within the tools and platforms used to conduct classes, and must not share the minor's data with third parties.

4. Identifying risks and warning signs

1. Personnel must remain alert to sudden changes in the minor's behaviour, isolation, anxiety, and avoidance of contact.
2. Personnel must respond to concerning entries or comments in the chat, as well as unusual statements made by the minor.
3. Identified risks must be reported in accordance with the reporting procedure.

5. Procedures for responding to suspected harm to a minor

1. How to report a concerning situation

Contact us if:

1. You are a child who feels uncomfortable, has been harmed, or is afraid of a person with whom they have classes,
2. You are a Guardian concerned about the behaviour of a teacher or employee,
3. You are a member of Fluentbe Personnel and have a reasonable suspicion that harm to a minor has occurred, that the Child Safeguarding Standards have been breached, or that any other behaviour has occurred which may endanger the safety of a minor.

2. Reporting procedure

1. Every member of Fluentbe Personnel is obliged to respond immediately upon obtaining information about Harm to a minor, suspected Harm to a minor, or a breach of a minor's safety (hereinafter: the Incident).
2. Report the concerning situation via the following form: https://forms.gle/gxWyrDR1KMfMWvJr7
3. In your report, describe the Incident in as much detail as possible, indicating all known circumstances and any available evidence or information that may be relevant to clarifying the matter, and document all material circumstances.
4. The person responsible for child safeguarding at Fluentbe will inform the Guardian in an appropriate manner, unless doing so could put the child at risk.
5. Every report is treated seriously, confidentially, and with due diligence. You may provide your details or remain anonymous. All Incidents are handled discreetly, and the safety of children is our priority.
6. Upon receiving a report, the person responsible for accepting it is obliged to prepare a note recording all material information and to forward it, together with notification of the Incident, to the Child Safeguarding Team (hereinafter: the Team). The Team means the team responsible for the implementation and monitoring of the Child Safeguarding Standards, appointed by Fluentbe's Management Board.
7. The note should include, in particular: the date and place of the Incident; information on who the Incident concerns; the persons making the report; evidence obtained in relation to the Incident; and the circumstances of its occurrence.
8. The Team is obliged to inform Fluentbe's Management Board of the occurrence of the Incident without delay and to initiate intervention measures appropriate to the circumstances of the case. Where the Incident concerns a member of the Team, the above measures shall be taken by another member of that Team, or Fluentbe's Management Board shall decide on another person responsible for carrying out the intervention measures relating to that Incident.
9. All information obtained in the course of handling an Incident shall be treated as confidential.
10. In the event of a suspected criminal offence to the detriment of a minor, or a threat to their life or health, Fluentbe shall immediately notify the relevant public authorities, in particular the Police, the public prosecutor's office, or the family court.
11. All actions taken by the Team are documented by means of an intervention record. The intervention record must describe all material circumstances relating to the Incident, the actions taken, and the steps taken following the intervention. A template for the intervention record is provided in Annex 1 to the Standards.

6. Procedures for responding to a breach of child safeguarding rules by Personnel

1. In the event of a breach of child safeguarding rules, the person in contact with the minor (e.g. a teacher conducting classes or an employee conducting meetings) shall be suspended from contact with the minor until the incident has been clarified.
2. An internal investigation shall be conducted to clarify the incident.
3. Fluentbe may apply disciplinary sanctions, including termination of cooperation and reporting the matter to the relevant authorities.

7. Ethical principles and code of conduct for teachers, employees, and other members of Personnel

1. Teachers, employees, and other members of Fluentbe Personnel who conduct online classes or meetings with minors, or who have any contact with them in connection with the service provided to them, shall maintain a relationship based on professionalism, respect, and safety.
2. Commenting on a minor's appearance, private life, or family situation, or raising topics inappropriate to the minor's age, is strictly prohibited.
3. All members of Personnel shall maintain appropriate standards of communication, use language appropriate to the minor's age, and foster an atmosphere conducive to the minor's psychological and emotional sense of safety.
4. Private contact with minors outside Fluentbe's official channels is completely prohibited, including contact via social media, messaging applications, telephone, or private email. It is also prohibited to form relationships of a personal nature or that suggest a private bond.
5. Personnel are obliged to be familiar with and to comply with the Child Safeguarding Standards in force at Fluentbe, and to respond to any signs that may indicate a threat to a child's safety.
6. The fact of having read the Standards is documented. A template declaration is provided in Annex 2 to the Standards.

8. Recruitment and vetting policy for Personnel having contact with Minors

1. Before being permitted to perform duties involving the conducting of classes, meetings, or other activities involving contact with a minor, Fluentbe carries out verification of the candidate in accordance with applicable law, including verification against the Register of Sex Offenders (hereinafter: the Register).
2. Every person applying for a position or for cooperation as a member of Personnel having contact with minors is required to submit documents and declarations via the recruitment form, in particular:
   1. a declaration regarding the provision and accuracy of the data necessary for verification purposes in the Register, in accordance with the content of Annex 3 to the Standards;
   2. a declaration, made under penalty of criminal liability, concerning the countries (other than the Republic of Poland) in which the candidate has resided over the past 20 years, in accordance with Annex 4;
   3. in the case of Polish residents: the original electronic file of the Information from the National Criminal Register (hereinafter: KRK) concerning themselves (obtained from the e-KRK system), bearing the electronic signature, personal signature, or trusted signature of the person authorised to issue it. The Information from the KRK may also be submitted in paper form (a document bearing an official seal and signature) to the Company's registered office;
   4. in the case of candidates from the United Kingdom: an official certificate of good conduct (ACRO Police Certificate or DBS Check / Disclosure Certificate);
   5. in the case of candidates from the USA: an official federal-level certificate of good conduct (Identity History Summary Checks / FBI Clearance);
   6. in the case of nationals of other countries: a certificate of good conduct issued by the competent authority of the country of origin or residence (obtained either directly from that country or via the Polish e-KRK system using the ECRIS procedure);
   7. where a given country does not maintain a criminal register or where obtaining such a certificate is not possible: a written declaration, made under penalty of criminal liability, confirming the absence of entries in that country's criminal registers and the absence of any orders prohibiting the candidate from working with children.
3. Information from the KRK, or an equivalent foreign certificate, shall be obtained in accordance with the requirements set out in the applicable legal provisions.
4. Fluentbe documents the completion of the legally required verification measures prior to permitting a person to have contact with minors.
5. Additionally, in respect of candidates for teaching positions, Fluentbe may carry out an assessment of professional competencies and experience in working with children and young people.
6. Permission to conduct classes with minors shall be granted only upon successful completion of the verification process and completion of the required training.
7. Where circumstances are identified that preclude a person from being permitted to carry out the activity, employment or permission to perform duties must be refused.
8. It is not permitted for a candidate to commence activity involving contact with minors before the verification procedure has been completed.
9. Documentation relating to candidate verification is retained in accordance with applicable law and data protection principles.
10. Where Fluentbe uses the services of subcontractors having contact with minors, such subcontractors are required to carry out the legally required verification measures in respect of their employees and associates, and to provide confirmation of their completion upon Fluentbe's request.
11. Fluentbe may carry out repeat verification of Personnel having contact with minors, in particular in the event of an extension of cooperation, the receipt of information that may affect the assessment of the person concerned, or changes in the law.

9. Training and awareness-raising

Every person newly employed or newly commencing cooperation who has contact with minors shall take part in initial training on child safeguarding. Personnel shall take part in refresher training no less frequently than once every 2 years, and on each occasion following any material update to the Child Safeguarding Standards or any change in the law relating to the protection of minors.

10. Protection of minors' data and privacy

1. Information about a minor is processed in accordance with applicable data protection law.
2. Only data necessary for the purpose of carrying out the process related to the conducting of classes shall be processed.
3. Recording of classes, including a minor's image or voice, is prohibited.

11. Monitoring, reporting, and improvement of the standards

1. Fluentbe maintains an internal incident register. The incident register is maintained by the person responsible for child safeguarding, who is a member of the Team. Access is restricted to members of the Team and the Management Board. Data is retained for a period of 6 years from the closure of the case.
2. The Standards are regularly reviewed and updated.
3. Any member of Personnel may raise concerns or propose improvements.
4. No less frequently than once every 2 (two) years, the Team shall carry out a review and evaluation of the state of compliance with, and awareness of, the Standards, and of the need for their updating, including by considering and, where possible, taking into account any submissions made in this regard.
5. Any member of Personnel is entitled to submit proposals for changes to the Standards.
6. The course and results of the review, including any conclusions and recommendations, shall be recorded in a written report and retained by the Company.
7. On the basis of the report, the Team shall submit to the Company's Management Board recommendations regarding the need to update the Standards. Where a decision is taken to update the Standards, the Team shall be responsible for preparing an updated version of the Standards, taking into account the conclusions of the report.
8. Updates shall be made in particular following changes in the law or the occurrence of significant events.
9. The Standards shall not be updated where the review referred to in paragraph 4 above indicates that no update is necessary.
10. Any member of Personnel is obliged to report instances of non-compliance with the Standards to the Team.

12. The Standards Team

1. In order to ensure the effective implementation and application of the Standards, the Company shall appoint the Team.
2. The Team's tasks shall include, in particular:
   1. supervising the proper implementation and application of the Standards within the Company,
   2. preparing Personnel and Subcontractors to apply the Standards, including organising training and providing ongoing support,
   3. receiving reports concerning Harm to minors and other irregularities,
   4. conducting investigations in the event of suspected Harm to a minor,
   5. coordinating support provided to Minors,
   6. maintaining an internal register of reports and documenting the course and conclusion of interventions,
   7. submitting notifications to the relevant public authorities in justified cases,
   8. periodically reviewing and updating the Standards.
3. Members of the Team are obliged to maintain the confidentiality of any information obtained in connection with the performance of activities concerning Minors, their parents or legal guardians, and Personnel, relating to the course of reports and investigations conducted.
4. The obligation of confidentiality also covers information disclosed in the course of reports, investigations, and interventions, regardless of the form in which it is recorded, and applies both during the performance of a function within the Team and after that function has ceased.
5. Disclosure of the information referred to above may take place only to the extent necessary for the performance of obligations arising from the law, in particular to the competent public authorities, or based on an express legal basis.
6. The Team may be contacted at: [email protected].

13. Annexes

1. Annex 1 – Intervention Record
2. Annex 2 – Declaration of Having Read the Standards
3. Annex 3 – Declaration on the Provision of Data for Verification Purposes
4. Annex 4 – Declaration Concerning Countries in Which the Candidate Has Resided Over the Past 20 Years

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Annex 1

INTERVENTION RECORD
(concerning suspected harm or infringement of the wellbeing of a minor)

Confidential Document

I. Basic Information

1. Date the record was prepared:
2. Place of the incident / intervention:
3. Full name of the person preparing the record:
4. Position / role:

II. Details of the Minor

1. Full name of the minor:
2. Date of birth / age:
3. Form of participation in the Event:
4. Full names of parents / legal guardians:

III. Information Concerning the Incident / Suspicion

1. Date and time of the incident or of the information being disclosed:
2. Description of the incident / circumstances justifying the intervention (the factual circumstances should be described, without assessments or interpretations):
3. Source of the information about the incident
   • own observation
   • information from the minor
   • information from another person (specify)
   • other (specify)

IV. Action Taken

1. Immediate action taken to protect the minor:
2. Persons informed of the incident:
   • parent / legal guardian
   • coordinator / director / supervisor
   • other persons (specify)
3. Was it necessary to notify the relevant institutions?
   • Police
   • District court – family division
   • Social welfare centre
   • other (specify)

Date and method of notification:

V. Further Steps / Decisions

1. Follow-up action agreed:
2. Person responsible for carrying out further action:

VI. Additional Remarks

VII. Signatures

1. Signature of the person preparing the record: Date:
2. Signatures of Team members:
   • Date:
   • Date:
   • Date:
   • Date:

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Annex 2

Declaration Concerning the Safeguarding of Minors

I, the undersigned, declare that:

I have read the document "Child Safeguarding Standards at Fluentbe" and undertake to comply with it strictly for the entire duration of my cooperation with Fluentbe, in particular to report information concerning incidents and actions inconsistent with its content.

Full name:

Date:

Signature:

1. Safe Contact with Minors

I understand the rules for safe contact with minors, in particular in the online environment, and I undertake to comply with them.

2. Consequences of Breaches

I acknowledge that a breach of the child safeguarding rules may result in the termination of cooperation.

3. No Criminal Record

I have not been finally convicted of any offence against minors, in particular:

• offences against sexual freedom and decency,
• offences against life and health,
• offences involving sexual exploitation, pornography, or human trafficking.

4. No Pending Proceedings

There are no criminal, administrative, or disciplinary proceedings pending against me concerning offences against minors.

5. Duty to Inform

I undertake to inform Fluentbe without delay of the initiation of any proceedings against me concerning offences against minors, or which may affect my ability to work with children.

6. Ethical Principles

I undertake to maintain a professional relationship with students and to comply with ethical principles, in particular the prohibition on private contact with minors outside official communication channels.

7. Truthfulness of the Declaration

I declare that all information I provide is true, and I am aware of my liability for making a false declaration.

Full name:

Date:

Signature:

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Annex 3

Warsaw,

Declaration on the Provision of Data for the Purposes of Verifying Individuals in the Register of Sex Offenders

I hereby provide the personal data necessary for verification in the Register of Sex Offenders:

PESEL number

first name

surname

maiden/family name

father's name

mother's name

date of birth

I declare that the above personal data is current and consistent with the facts. I acknowledge that I am obliged to inform the Company of any change to my personal data. I am aware of my criminal liability for making a false declaration.

Information on the processing of personal data is set out below.

(date, legible signature of the person being checked)

In accordance with Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR"), we inform you that:

1. The controller within the meaning of Article 4(7) GDPR in respect of personal data provided under the declarations and documents confirming compliance with child safeguarding obligations is Fluentbe Sp. z o.o., with its registered office in Warsaw at ul. Biała 4/81. The controller may be contacted by email at: [email protected].
2. Fluentbe declares that it has appointed a Data Protection Officer, who may be contacted regarding matters relating to the processing of personal data by email at: [email protected].
3. Personal data is processed for the purpose of verification in the Register of Sex Offenders and the performance of obligations relating to child safeguarding standards, to the extent necessary to confirm compliance with the requirements set out in the applicable law.
4. The legal basis for the processing of the data is Article 6(1)(c) GDPR, i.e. the processing is necessary for compliance with a legal obligation to which the Controller is subject, arising from Article 21 of the Act of 13 May 2016 on Counteracting the Threat of Sexual Offences and the Protection of Minors (consolidated text, Journal of Laws of 2023, item 1304, as amended).
5. The personal data will not be transferred to other recipients.
6. The personal data provided in the declaration is processed for the time necessary to carry out verification in the Register of Sex Offenders. Following verification, the data is promptly deleted, save that information confirming that verification took place shall be retained for the period required by law or necessary to secure any claims. The remaining data processed as part of the submitted documents will be processed for the duration of the cooperation and for up to 6 years following its termination.
7. Persons who have provided their personal data have the right to request from the controller access to their personal data, its rectification, erasure, or restriction of processing, or to object to its processing. A request for erasure of data or an objection may be made following verification in the Register of Sex Offenders.
8. Persons referred to in paragraph 1 above have the right, in connection with the processing of their personal data, to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).
9. The provision of personal data is mandatory and arises from the law, namely the Act referred to in point 4 above. Refusal to provide it will make it impossible to carry out verification, and consequently to establish cooperation or to participate in activities carried out by the controller involving minors.
10. The personal data will not be processed in an automated manner, including for the purposes of profiling.

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Annex 4

Warsaw,

Declaration

Pursuant to Article 21(5) of the Act of 13 May 2016 on Counteracting the Threat of Sexual Offences and the Protection of Minors (consolidated text, Journal of Laws of 2023, item 1304, as amended), I declare that, over the past 20 years, I have resided / have not resided* in a country other than the Republic of Poland and the country of my nationality.

If applicable, I declare that the countries in question were as follows, for which I enclose the corresponding criminal record information:

I declare that I am aware of my criminal liability for making a false declaration.

(signature of the person)

*delete as appropriate