MINOR PROTECTION STANDARDS

§ 1. General provisions

1.

The Standards set out the rules ensuring safe relations between the personnel of NutriLogic Sp. z o.o. (hereinafter: the “Company”) and minors, the rules for responding to the harming of minors and the rules for documenting incidents.

2.

The welfare and safety of the minor take precedence over the interests of the Company, the Club and sporting results.

3.

The Standards apply to every person who, on behalf of the Company or through the Platform, has contact with minors or access to their data, in particular the Company's employees, collaborators, trainees and volunteers, and the Specialists (hereinafter collectively: “personnel”). Acceptance of the Standards is a condition for starting cooperation and, in the case of a Specialist, a condition for being admitted to work with minors on the Platform.

4.

The terms used in the Standards mean:

a)

minor - a person who has not reached the age of 18 and is supervised by the Company;

b)

parent - a parent or legal guardian of the minor;

c)

harm - any act or omission that endangers the safety, health or development of the minor, including physical, psychological and sexual violence, neglect, exploitation and online violence, regardless of whether the perpetrator is a member of the personnel, a parent, a person associated with the Club, a peer or a stranger;

d)

Coordinator - the person responsible for applying the Standards, specified in § 2;

e)

Platform - the nutrilogic.io website, including the Supervised Athlete Panel and the chat;

f)

Specialist - a dietitian or a member of the Scientific Team who, under an agreement with the Company, performs its services and supervises minors through the Platform.

§ 2. Persons responsible

1.

The Coordinator of the Standards is the President of the Management Board of the Company. In the absence of the Coordinator, or where a report concerns the Coordinator, the Coordinator's tasks are performed by a person from among the personnel designated by the Management Board.

2.

The Coordinator's tasks include in particular:

a)

receiving reports of events endangering a minor and providing support to the minor;

b)

conducting interventions, filing notifications and keeping the incident register;

c)

preparing the personnel to apply the Standards and documenting training;

d)

monitoring and updating the Standards.

3.

The Management Board adopts and approves the Standards, provides the resources necessary to apply them and takes decisions on removing a member of the personnel from contact with minors.

4.

Every member of the personnel knows the Standards, responds to signs of harm and promptly reports them to the Coordinator.

5.

Reports are also accepted from parents, minors and Clubs, by electronic means at contact@nutrilogic.io with the note “Minor protection” or directly to the Coordinator. A report may be anonymous.

§ 3. Recruitment and vetting of personnel

1.

Before admitting a person to contact with minors, the Company:

a)

checks the person in the Register of Sexual Offenders with restricted access and keeps a printout of the result;

b)

obtains from the person information from the National Criminal Register as regards the offences specified in Article 21 of the Act of 13 May 2016 on counteracting the risks of sexual offences and protecting minors;

c)

obtains from the person a declaration of the countries of residence in the last 20 years (Appendix No. 1) and, if the person has resided abroad or holds citizenship of another country, information from the criminal register of that country or a declaration made under pain of criminal liability if no such register is maintained;

d)

verifies the qualifications appropriate to the assigned role;

e)

obtains from the person a declaration of having read the Standards (Appendix No. 2) and conducts training.

2.

The agreement with a member of the personnel contains an obligation to apply the Standards, to maintain confidentiality and to report incidents, and the Company's right to immediately remove the person from contact with minors.

3.

The check in the Register of Sexual Offenders is repeated at least once a year. Vetting documents are kept in personnel files or in the cooperation documentation, with access restricted to the Management Board and the Coordinator.

§ 4. Rules for safe relations between personnel and minors

1.

Contact with a minor serves solely to supervise the minor through the Platform in the area of supplementation, nutrition and monitoring of sporting results. The personnel do not make diagnoses, do not treat and do not recommend medicines. The personnel act professionally and transparently and are ready to explain to the parent the actions taken.

2.

The personnel are obliged to:

a)

treat the minor with respect, listen to the minor and take their concerns seriously;

b)

speak about the body, body weight and nutrition in a factual manner, focused on health and sporting performance, without judgement;

c)

adapt recommendations to the minor's age and the information about their health provided by the parent, not recommend weight-reduction diets or supplements not intended for minors and, in case of doubt, recommend that the parent consult a physician;

d)

inform the parent of recommendations and of signs indicating the need for a medical consultation;

e)

maintain confidentiality, provided that they must not promise the minor secrecy in matters concerning the minor's safety;

f)

report to the Coordinator any situation causing concern, including one concerning another member of the personnel.

3.

The personnel are prohibited from:

a)

contacting the minor via private messaging apps, social media, a private telephone number or private email, and from inviting the minor to be friends;

b)

meeting the minor privately or outside scheduled online conversations;

c)

asking for photos or recordings of the minor's figure and accepting them, provided that a measurement requiring a photo is taken solely on the Platform, with the parent's consent and in sports clothing;

d)

commenting on the minor's appearance, body or attractiveness, making jokes of an ambiguous nature and using vulgar language;

e)

shaming the minor because of body weight or nutrition, exerting pressure and making threats;

f)

giving gifts, money or privileges unrelated to the services;

g)

selling or giving the minor supplements without the parent's knowledge;

h)

offering prohibited substances, alcohol, nicotine products or intoxicating substances;

i)

recording and disseminating the minor's image or data without the required consent;

j)

entering into a romantic or sexual relationship with the minor and engaging in any behaviour of a sexual nature.

4.

A breach of the rules set out in paragraph 3 results in immediate removal from contact with minors and, where a criminal offence is suspected, notification of the competent authorities.

§ 5. Safe online communication and protection of image and data

1.

Communication with a minor takes place solely on the Platform. Chat conversations are saved and the parent may read them.

2.

Direct contact between a member of the personnel and a minor is possible only after the parent has given consent. Without consent, the member of the personnel contacts the parent.

3.

Video calls take place using a tool designated by the Company, with the parent present or, in the case of a minor who has reached the age of 16, with the parent's knowledge. Calls are not recorded.

4.

The personnel use only password-protected business accounts and do not save minors' data on private devices.

5.

The Company does not publish photos, recordings, names or results of minors, including in promotional materials, without the written consent of the parent and the minor specifying the purpose and place of publication. Consent may be withdrawn at any time.

6.

The personnel respond in accordance with § 7 to disclosed online violence, in particular harassment, blackmail and the sending or demanding of intimate photos.

§ 6. Signs of harm

1.

The personnel pay particular attention to the following signs that may indicate harm to a minor:

a)

in the area of nutrition and body - rapid weight loss, hiding meals, vomiting after eating, obsessive calorie counting, loss of menstruation in a female athlete;

b)

in the area of pressure from the environment - a demand for weight reduction by a coach or parent, punishment for body weight, forcing training despite injury or illness;

c)

in the area of substances - offers of doping agents or medicines without indication, giving supplements without the parent's knowledge;

d)

in the area of mental health - withdrawal, anxiety, statements about self-harm or about life having no meaning;

e)

in the area of violence - signs of beating, accounts of violence at home or in the club, neglect as regards food or medical care;

f)

in the area of sexual violence and online violence - knowledge of sexuality inappropriate for the age, mentions of “secrets” with an adult, blackmail, intimate photos.

2.

The occurrence of a sign does not determine that harm has occurred. The personnel do not conduct their own investigation and do not interrogate the minor, but report the sign to the Coordinator.

§ 7. Intervention procedure

1.

Where the life or health of a minor is at risk, a member of the personnel immediately calls for help on the emergency number 112 and then notifies the Coordinator.

2.

A member of the personnel who has noticed a sign of harm or has received a confidence calmly listens to the minor, does not promise secrecy, does not ask leading questions and does not confront the suspected person. The member of the personnel prepares a note containing the facts and the minor's statements and passes it to the Coordinator on the same day.

3.

The Coordinator opens an intervention card (Appendix No. 3) and takes the actions appropriate to the type of situation:

a)

where a criminal offence against a minor is suspected, in particular sexual exploitation, abuse or online violence - immediately notifies the Police or the prosecutor's office, without informing the parent if the parent may be the perpetrator;

b)

where there is harm or neglect by a parent that does not constitute a criminal offence - files a request with the family court for an examination of the family's situation; the Company does not initiate the “Blue Card” (Niebieskie Karty) procedure, but may inform the social welfare centre or the Police, which are authorised to initiate it;

c)

where there is harm by a person associated with the Club or by a member of the personnel - the member of the personnel is immediately removed from contact with minors, the Coordinator informs the parents and, in the case of a person associated with the Club, also the Club's management board; where an offence is suspected, point a) applies;

d)

where there is a health signal, in particular eating disorders, suicidal thoughts or pressure concerning body weight - holds a conversation with the parents and recommends a medical or psychological consultation, and where life is at risk, applies paragraph 1.

4.

Notification of the competent authorities does not require the consent of the parent or the Club's management board.

5.

After the actions are completed, the Coordinator draws up the support plan referred to in § 8 and closes the intervention card.

§ 8. Support plan for the minor

1.

The support plan is determined by the Coordinator together with the parent, if the parent is not suspected of harming the minor, and, where possible, with the participation of the minor.

2.

The support plan specifies in particular:

a)

actions protecting the minor from further harm, including a change of Specialist, suspension of services or removal of a member of the personnel;

b)

an indication of where the parent can seek specialist help, including medical and psychological help, and the helplines listed in Appendix No. 5;

c)

changes in the supervision of the minor, including suspension of supplementation until consultation with a physician chosen by the parent;

d)

the person responsible for contact with the family and the date for assessing the effectiveness of the support.

3.

The Company does not provide psychological therapy. The task of the personnel is to notice the risk, respond and refer the minor to appropriate help.

§ 9. Documenting incidents

1.

Every intervention is documented in an intervention card (Appendix No. 3), covering a description of the sign, the actions taken, the notifications filed and the support plan.

2.

The Coordinator keeps the incident register (Appendix No. 4) and keeps copies of notifications.

3.

The documentation is confidential. Access to it is available only to the Coordinator, the person deputising for the Coordinator and the Management Board, and to law enforcement authorities and courts at their request.

4.

The documentation is kept in a locked cabinet or an encrypted repository for 10 years from the closure of the case, but not shorter than until the minor reaches the age of 25.

5.

The personal data contained in the documentation is processed on the basis of Article 6(1)(c) and Article 9(2)(g) of the GDPR in conjunction with the provisions of the Act of 13 May 2016 on counteracting the risks of sexual offences and protecting minors.

§ 10. Training of personnel and availability of the Standards

1.

Every member of the personnel, before first contact with a minor, reads the Standards, takes part in training conducted by the Coordinator and signs a declaration (Appendix No. 2). Training is repeated at least once a year and after every change to the Standards. The Coordinator keeps a list of persons trained.

2.

The Standards are made available:

a)

in full version - on the nutrilogic.io website;

b)

to parents - together with the documents concerning consent to the supervision of a minor;

c)

to minors - in a short version (Appendix No. 6) on the Platform;

d)

to Clubs - together with the cooperation agreement.

§ 11. Monitoring and updating of the Standards

1.

The Coordinator assesses the Standards at least once every 2 years, and also after every serious incident and after a change in the provisions of law.

2.

The assessment covers in particular the personnel's knowledge and application of the Standards and an analysis of reports. For the purposes of the assessment, the Coordinator may collect anonymous opinions from personnel, parents and minors.

3.

Changes to the Standards are approved by the Management Board and announced to the personnel, parents and Clubs.

§ 12. Final provisions

1.

The Standards enter into force on 22 October 2026.

2.

A member of the personnel who started cooperation before the date on which the Standards entered into force reads them and signs the declaration (Appendix No. 2) within 14 days of that date.

3.

Matters not regulated in the Standards are governed by provisions of law, in particular the Act of 13 May 2016 on counteracting the risks of sexual offences and protecting minors.

......................................................

President of the Management Board of NutriLogic Sp. z o.o.

Appendix No. 1

Declaration of countries of residence and no criminal record

I, the undersigned ............................................................................................................, born on ..................................................., declare that in the last 20 years I have resided in the following countries other than the Republic of Poland and the country of my citizenship: ............................................................................................................................................

I further declare that I have not been convicted of the offences specified in Article 21 of the Act of 13 May 2016 on counteracting the risks of sexual offences and protecting minors. I am aware of the criminal liability for making a false declaration.

......................................................

date and legible signature

Appendix No. 2

Declaration of having read the Minor Protection Standards

I, the undersigned ............................................................................................................, holding the position of ........................................................................., declare that I have read the Minor Protection Standards in force at NutriLogic Sp. z o.o., have completed training in their application and undertake to comply with them, in particular the rules set out in § 4 and § 5 and the obligation to report signs of harm to the Coordinator.

......................................................

date and legible signature

Appendix No. 3

Intervention card

Case number: ..............................................................................................................

Minor's first name and surname, age, Club: .........................................................................

Date and manner of disclosure (confidence, sign, report): ..................................................

Reporting person: ..........................................................................................................

Description of the situation (facts, minor's statements): .....................................................................

........................................................................................................................................

Type of situation under § 7(3): ...................................................................................

Actions taken and their dates (112, notification, request to the court, removal, conversation with parents): ........................................................................................................................................

Support plan and person responsible: ...............................................................................

Date of closure of the case: ..................................................................................................

......................................................

signature of the Coordinator

Appendix No. 4

Incident register

The register is kept by the Coordinator. For each incident the register records, in order: the case number, the date of disclosure, the type of sign, the type of situation under § 7(3), the notifications filed (authority and date) and the status of the case. The register is kept in electronic form in an encrypted repository with access restricted to the Coordinator, the person deputising for the Coordinator and the Management Board.

Appendix No. 5

Where to seek help

1.

112 - emergency number in a situation threatening life or health.

2.

116 111 - free, round-the-clock helpline for children and young people.

3.

800 12 12 12 - Children's Helpline of the Ombudsman for Children.

4.

800 100 100 - helpline for parents and teachers on child safety.

5.

800 120 002 - National Helpline for Persons Experiencing Domestic Violence “Blue Line” (Niebieska Linia).

Appendix No. 6

Minor Protection Standards - version for athletes

1.

We help you eat wisely and choose supplements so that you stay healthy and get better at your sport. Your health is more important than the result.

2.

We talk to you only on the NutriLogic Platform. None of us will write to you on a private messaging app or on social media.

3.

None of us will ask you for photos of your body, comment on how you look or give you any substances without your parents knowing.

4.

If someone - from NutriLogic, from your club, from home or from the internet - hurts you, pressures you to lose weight or makes you feel unsafe, tell a parent or a person you trust, or write to us: contact@nutrilogic.io.

5.

You can also call 116 111 free of charge and anonymously. If you are in danger, call 112.

6.

We take every report seriously. You will not get into any trouble because of it.