Legal

Child protection and ESCNNA prevention policy

Last updated: August 3, 2026

The sexual exploitation and abuse of minors in Colombia is punished criminally and administratively under the laws in force.

ENTREFASE S.A.S., operator of Club Fase II, adopts this policy for the prevention of the Commercial Sexual Exploitation of Children and Adolescents (ESCNNA), under Law 679 of 2001, Law 1336 of 2009, Law 1329 of 2009 and the Childhood and Adolescence Code (Law 1098 of 2006). In case of discrepancy, the Spanish version prevails.

1. Zero tolerance

Our position admits no nuance: zero tolerance for any form of sexual exploitation, abuse, human trafficking or use of minors. This policy binds management, employees, performers, contractors, suppliers and guests alike.

2. Absolute ban on minors entering

Entry by anyone under 18 is strictly prohibited, with no exceptions — being accompanied or authorised by an adult does not permit it. We apply:

  • ID verification at the door for every person entering, with no exceptions based on appearance, nationality or who they are with.
  • Refusal of entry where there is any reasonable doubt about age or document authenticity. When in doubt, no entry.
  • Immediate removal and activation of the response protocol if a minor is found inside the venue.

3. The venue does not offer or broker sexual services

Club Fase II is a venue for live artistic performances and the serving of drinks. It does not offer, promote, broker or tolerate sexual services of any kind, on or off its premises. Guests, performers and staff are prohibited from offering, requesting or facilitating such services in the venue or its surroundings.

4. Concrete commitments

  1. To refrain from offering, in promotional programmes or any advertising material, plans involving the sexual exploitation of minors.
  2. To refrain from giving information or facilitating access, transport or contact that could lead to the sexual exploitation of minors.
  3. To prevent minors from entering the venue and to prevent our facilities being used for any purpose connected with ESCNNA.
  4. To train all staff — door, bar, waiting staff, security and performers — to recognise warning signs and follow the reporting procedure.
  5. To report to the competent authorities any fact or suspicion of ESCNNA that comes to our knowledge, and to cooperate fully with investigations.
  6. To display prominently in the venue the legal notice on the criminal and administrative penalties applicable to the sexual exploitation of minors.
  7. To review this policy periodically and update it whenever the law or our operating conditions change.

5. Warning signs that trigger the protocol

Staff are instructed to report immediately, among others, the following situations:

  • A person who appears to be a minor trying to enter or present in the venue.
  • An ID document showing signs of tampering, or that does not match its bearer.
  • An adult attempting to enter accompanied by someone who appears to be a minor.
  • Guests asking about the availability of minors, or hinting in that direction.
  • Third parties in the surrounding area offering contact with minors.

6. Procedure for an incident or suspicion

  1. Immediately inform the duty manager or head of security.
  2. Move the possible victim to safety, without exposing or questioning them.
  3. Prevent the alleged offender from leaving where it is safe to do so, without putting anyone at risk.
  4. Call the National Police (123) and report to the competent authorities.
  5. Preserve CCTV records and make them available to the authorities.
  6. Document the incident and the actions taken internally.

7. Reporting channels

Anyone can report anonymously. No proof is required — reasonable suspicion is enough.

8. Legal framework

  • Law 679 of 2001 — statute to prevent and counter the exploitation, pornography and sexual tourism involving minors.
  • Law 1336 of 2009 — strengthens Law 679 against ESCNNA and broadens the duties of venues.
  • Law 1329 of 2009 — criminalises the demand for commercial sexual exploitation of minors.
  • Law 1098 of 2006 — Childhood and Adolescence Code.
  • Law 1801 of 2016 — National Code of Security and Coexistence.
  • Decrees 0247 and 0248 of 2024, City of Medellín — reinforced measures against commercial sexual exploitation in El Poblado and surrounding areas, which this venue observes in full.

9. Effective date and responsibility

This policy is effective from August 3, 2026 and is mandatory. Its application and updating are the responsibility of the Management of Club Fase II, at Cra. 44 #30-27, El Poblado, Medellín, Antioquia, Colombia.

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