Employers in Voluntary Housing
Model Code of Conduct for Staff
MODEL CODE OF CONDUCT FOR STAFF
INTRODUCTION
No Code of Conduct can hope to spell out the appropriate behaviour for every situation with which you might be contracted, nor should it seek to do so. In the final analysis, the Housing Association relies on each of us to make a judgement on what is right and proper in any particular situation.
The following may help you decide how to act when faced with a difficult decision: -
Is anyone's life, health or safety endangered by my action?
Does my action 'feel' right? Does it meet my personal code of behaviour? Could I justify my action to a customer, committee member, or close colleague?
Is my action legal, and does it comply with Housing Association policy and approved practice?
Does my intended action appear reasonable? Would I be able to justify it to the local news media?
Would I be compromised if my intended action became known to my manager, fellow employees, committee, or friends?
Ethical dilemmas occur in many aspects of business life. In order to operate this Code of Conduct effectively, the following should be in place: -
the Housing Association should maintain a register of interests of individual staff which discloses, at a minimum, their other employment, positions of public responsibility, membership of any other related organisation and any financial interests which may relate to the work of the Housing Association;
a policy on expenses for staff;
a code of governance for Committee Members;
also a register for recording any gifts or hospitality offered or received.
Some of the most difficult dilemmas that may occur, and rules and guidance are given below: -
GENERAL CONDUCT
You are expected to carry out your duties in accordance with the employer’s policies and procedures.
High standards of personal conduct are expected of employees. You should show courtesy, efficiency, reliability, sobriety and punctuality.
The following three extracts are direct quotes from your Conditions of Service:
- Use of Official Premises
“Employees may not use official premises for unofficial purposes at any time without the prior approval of the Management Committee.”
- Other Employment/Activities
“Employees may not accept a post or undertake any occupation or activity which would require their attendance at any time during office hours and/or prejudice the proper performance of their duties for the Association/Co-operative. In exceptional circumstances, permission may be granted by the Management Committee for such activities. This permission should therefore be sought in advance and in any case where the employee is in doubt as to whether this condition would apply.”
- Private Telephone Calls/Faxes/e-Mails
“The controlled use of official telephone lines for private use is allowed within reason. All non local use must be advised in advance and paid on receipt of itemised telephone bill.”
FINANCIAL CONDUCT
You must ensure that you:
Use funds and resources for the purpose intended, and in a responsible and lawful manner.
Safeguard them from abuse, theft or waste.
Strive for value for money.
Apply and observe Association's financial regulations, and internal controls.
You must be aware that it is a criminal and disciplinary offence to corruptly receive or give any gift, loan, fee, reward or other advantage in return for doing (or not doing) anything, or showing favour (or disfavour) to any person or organisation.
Staff are expected to report to their manager any breaches of this code.
RELATIONSHIPS - COMMITTEE
If you work brings you into contact with the Committee, mutual respect between you and them is essential. Close personal familiarity could be prejudicial to the good running of the organisation, and should be avoided.
You should not use informal channels to influence the Committee on Association business.
It then makes sense for those employees who find that their friendship or close relationship, or affair may cast doubt on the objectivity of their decision-making to advise their Director or line manager. When to advise will be a matter of judgement for the individuals concerned, but is should certainly be there before there is a likelihood of them leaving themselves open to allegations of bias or favouritism. (Individuals can discuss in confidence their own situation with the Employee Counselling Service on 0800 435 768).
RELATIONSHIPS - CONTRACTORS, SUPPLIERS, CONSULTANTS
All current or past, private or business, relationships with current, or potential contractors (etc) should be declared to your manager. Whether you are involved in their appointment or not.
This is also covered by Conditions of Service, as under:
“An employee must, as soon as practicable, bring it to the attention of the Chair of the Management Committee, in writing, where they discover (a) the Association/Co-operative has or proposes to enter into a contract or an appointment, and (b) they have a pecuniary and/or private interest in that contract or appointment. This interest can be direct or indirect (i.e. they need not themselves be a party to it).”
EQUALITY
You should ensure that Association's policies are complied with both in the letter and in the spirit.
BALANCING CONFIDENTIALITY AND OPENNESS
The law or rules requires that certain information is available to members, auditors, and Scottish Homes. You should be aware of these requirements and act accordingly.
You equally need to be aware of which information needs to be kept confidential (e.g. employee files) and obtain written permission before releasing any such information.
Here’s another extract from your Conditions covering Disclosure of Information: -
“In the course of your employment you may have access to confidential information about the business of your employer and of other organisations. It is forbidden, either orally or any other way, to disclose such information to another party, without first obtaining the written permission of the Management Committee.
The permission of the Director is also required before confidential correspondence or documents are removed from the work premises.”
TENDERING AND PURCHASING
Fairness and impartiality is required. All orders and contracts must be awarded on merit, by fair competition.
You must not disclose confidential information on tender costs, and where possible, and where alternatives exist, you should avoid the use for private purposes of any firms working for the Association.
EMPLOYMENT MATTERS
Staff involved in making appointments should ensure that these are based on merit alone.
Personal preferences should not influence judgements to be made.
The law and Association employment procedures must be observed scrupulously and impartially, subject always to the duty to act fairly.
OUTSIDE ACTIVITIES
As a good employer, the Association has no wish to interfere in the private lives of employees. However, there are occasions where an employee's outside activities can affect their work, or the interests of their employer.
Some basic rules: -
Any possible conflict, tell your manager, and seek necessary written permission.
If it will overlap with work, don't start till written permission is granted.
This applies to voluntary and unpaid work.
No paid or outside work should be undertaken at your place of work, or require the use of office facilities.
POLITICAL, CAMPAIGNING AND PUBLIC ACTIVITIES
It is crucial that officers carry out their work without any bias towards any political or other group.
You must follow the lawful expressed policies and procedures of the Association as your employers, and must not allow you own personal or political opinions to intervene with your work or impartiality.
None of the above impinges on your rights to be an active citizen or, for example, an active trade unionist and acting in such capacity.
GIFTS AND HOSPITALITY
The principle of integrity requires that staff should not place themselves under an obligation that might influence, or be perceived to influence, the conduct of their duties. This means that the receipt of gifts and hospitality must be subject to clear and sweeping restrictions, and that any that are accepted must be declared and recorded.
Your Conditions of Service mention this too:
“Employees should not accept any gift, favour or hospitality which is intended as, or might be deemed by others to have the effect of an inducement. It is normally clear whether an offer of hospitality etc. from another party might be considered excessive or unreasonable. However, if there is any doubt contact your line manager.”
DECLARATION OF INTERESTS
You must ensure that your private or personal interests do not influence your decisions, and that you do not use your position to obtain personal gain of any sort, either for yourself directly, or for your families, friends or associates.
You must declare any actual or potential conflicts of interest arising from previous sections of this code in the Association's register of interests.
PUBLIC STATEMENTS
The Housing Association has a policy on handling media inquiries. You must comply with this policy. However, for guidance, staff must be aware that their comments on issues which are subject to debate must be limited to professional advice, fact, legal and financial implications. This does not circumscribe their duties and responsibilities but to prevent staff being considered to be participants, or biased, in campaigns or politics, which directly affect their employer.
A final quote from your Conditions covers this:
“No employee may publish any material or deliver any lecture or address relating specifically to their Association/Co-operative or its business without prior approval. This approval should be requested and given in writing by the Management Committee or appropriate Sub Committee.”
DECLARATION FORM
This form is to record any actual or potential conflict in interest arising under the code of Conduct. Please use a separate form for each conflict that you need to declare. Leave blank any boxes that are not relevant to the declaration. Please add any other relevant information on another sheet of paper which should also be signed and dated.
Your details
1Name
2Job Title
3Place of Work
4Date of Declaration
Details of the Declaration
5Please give details of
who this declaration
concerns - you, a family
member, friend or
associate?
6Please give details of any
firm or business
involved
7Please give details of any
payment, benefit,
transaction, contract,
property, gift or
hospitality that is
involved (with date)
8Please give details of any
proposed job application or
other employment issue which
may represent a conflict.
9Is there any reason why
this declaration should be
regarded as confidential?
Please give details.
Signed (employee):Signed (manager):
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