Our Code of Conduct Trust is not given. It’s earned
www.britishcouncil.org
Contents Foreword from Chief Executive. . ........................................ 01 Our values.................................................................................................. 02 Introduction. . .......................................................................................... 03 Our code of conduct......................................................................04 1. Legal compliance.............................................................................................. 5 2. Working together ............................................................................................. 5 3. Equal opportunities.......................................................................................... 5 4. Health and safety.............................................................................................. 5 5. Child protection................................................................................................. 6 6. Working with others. . ........................................................................................ 7 7. Dealing with competitors and suppliers....................................................... 7 8. Upholding public trust.. .................................................................................... 7 9. Confidentiality and information security...................................................... 7 10. Looking after our reputation........................................................................ 8 11. Financial management and accountability. . ............................................... 8 12. Property and assets..................................................................................... 10 13. IT and telecommunications . . ...................................................................... 10 14. U sing funds and resources..........................................................................11 15. Gifts, entertainment and payments. . ..........................................................11 16. Conflicts of interest...................................................................................... 13 17. Duty of disclosure......................................................................................... 13 18. Personal relationships at work .................................................................. 14 19. Recruiting relatives and friends................................................................. 14 20. Dealing with wrongdoing. . ........................................................................... 14
Breaches of the Code. . ................................................................... 16 Further Sources of Information....................................... 17
Our Code of Conduct
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How we behave says who we are
As the world’s leading cultural relations organisation, the British Council touches the lives of millions of people each year. For every single one of them, the way we conduct ourselves speaks volumes about who we are, and what we stand for. Our Code of Conduct sets the standards for the way we work in all our activities and locations. These standards are designed to help us behave in ways that earn people’s trust, create understanding and build mutual respect. Ensuring that we meet them is essential both to our reputation and to the success and effectiveness of our work. Everything we do must bring benefit to the UK and to the countries we work with. We are venturing into new ways of meeting that purpose by combining our public service role with an entrepreneurial drive involving partnerships, contracts work and paid-for services. As a result, our network of relationships is becoming wider and more complex, while the environment around us continues to change rapidly. This means it is even more important for us to be very clear about our values and about how we conduct ourselves, and take responsibility for our actions, both as individuals and as an organisation. Please read the Code of Conduct carefully, familiarise yourself with it and refer to it whenever you need to. Thank you.
Martin Davidson Chief Executive
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Our Values Our values underpin everything we say and do Our Code of Conduct sets standards for the way we work that are consistent with the British Council’s values. Our five values underpin everything we say and do, how we work with people, behave towards them and communicate. Here is a brief description of what each one means to us:
Valuing people
Creativity
The world is a diverse place, which is why our work starts by giving everyone the chance to participate. This means treating people with courtesy and respect. By listening and responding in a helpful way, we are able to unlock potential and help people be the best they can be.
Creativity is the key that will unlock the world’s potential. We are constantly looking for new sources of inspiration, encouraging resourcefulness and the development of new ideas that will shape the future.
Integrity
As leaders, we understand our responsibility to deliver excellence every time. Setting the highest standards for ourselves and expecting the same of others means that we’ll stay true to our values.
Keeping our promises, and being consistent in what we say and do, builds trust. We are always honest and take responsibility for our actions.
Mutuality Effective relationships are the heart of our work. It’s a two way exchange: we learn from all those we interact with and they learn from us, all with a view to advancing the creation of global citizens.
Professionalism
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introduction Circumstances may change, but our principles don’t
These principles are here to help us
We are an organisation that respects diversity, believes in equal opportunities, sets high standards, and works professionally and creatively to help build a more inclusive and prosperous world.
Our Code of Conduct sets out the principles that everyone who works for the British Council must follow. They cover most of the issues that we are likely to have to deal with.
We’re here to create opportunities and build trust internationally. To do this effectively, the way we behave must reflect our values and stand up to scrutiny wherever we work.
We are all responsible for making sure that our own actions and behaviours follow the code and, as you’d expect, breaches of the code will be investigated and disciplinary action may be taken.
If in doubt, seek advice Our Code of Conduct applies worldwide. If there are unavoidable legal or other circumstances that make applying it difficult in a particular location, the country director should speak to the Chief Executive or a nominated senior manager. The code can’t cover everything. So, when dealing with an issue that it doesn’t address directly, we should use our values to help resolve it, speak to a manager or consult the Human Resources, Finance or other relevant intranet site. In the same way, if you need clarification about anything in the code, talk to your manager or Human Resources, who’ll be able to help you, or read the relevant policy in detail. You will find links to all of the policies mentioned in the code at the end of this document.
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Our Code of Conduct
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1. Legal compliance
3. Equal opportunities
4. Health and safety
Respecting the law
Avoiding discrimination
Looking after people
We are committed to complying with the law in all the countries and territories where we work. This is a fundamental principle and we must follow it in all our dealings and behaviours.
The British Council is an equal opportunities employer. This means that we are committed to ensuring that there is no unjustified discrimination on the basis of any of the following: age, disability, gender, including transgender, having or not having dependants, HIV/AIDS status, marital status, political opinion, race, religion and belief, sexual identity, socioeconomic background, spent convictions, trade union activity or membership, work pattern or any other such grounds.
As far as is reasonably practicable, the British Council makes every effort to ensure the health and safety of everyone who works for us, wherever they may be working, and also of the visitors, students, contractors and others who use our premises.
In addition, all our activities must comply with the UK’s charity law and be for the public benefit. If there is any doubt or dispute, your senior manager should seek advice from the Legal Team.
2. Working together Respecting our colleagues As individuals, we should always treat colleagues with politeness and respect, and as a global organisation, we should show respect for local cultures and customs. If you are affected by what you believe to be unacceptable or disrespectful behaviour, you should consult your line manager, senior manager or Human Resources Business Partner. If you’re a member of a trade union or staff association, consult your representative. Should you witness what you believe to be unacceptable behaviour towards others, even if you’re not directly affected by it, you can raise specific concerns under our Speaking-up Policy, which is available to view on the intranet, and is set out in brief as principle 20 of this code.
The principles which underlie our Equal Opportunities Policy apply worldwide and must be followed unless local law restricts this in some way. If you believe such a restriction exists, please consult the Diversity Unit for guidance. We are all responsible for making sure that this policy is put into practice. So we should each take the time to make sure that we are familiar with its terms and not allow discrimination to affect our judgement or behaviours, either at work or in dealing with others outside the British Council. You’ll find the policy in full and more information about equal opportunities and diversity on the intranet.
We should all take responsibility for our own health and safety and, so far as we are able, that of others. We should observe our Health and Safety Policy, which is available in every British Council office and on our intranet site, and follow the regulations and procedures that apply in the workplace. We should also complete mandatory health and safety training. Contact the Health and Safety Adviser in Enterprise Risk Management if you need further guidance or information.
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5. Child protection Caring for children We have a fundamental duty of care for all the children who engage in activities with us. We recognise our responsibility to protect them from abuse, exploitation and negligence, applying zero tolerance and aiming to create a safe environment for them. (A child is defined as any young person under the age of 18, regardless of the age of majority in the country where the child is, or his or her country of origin – UN 1989). Everyone who works at the British Council, or on our behalf, must make sure that they are familiar with our mandatory Child Protection Policy, available on the intranet, and must also read and follow the Child Protection Code of Conduct that is outlined in the policy. We all share responsibility for implementing this and must always act on any allegations or concerns about actual or suspected cases of abuse. If you have any concerns or questions, you should contact the child protection focal point in your country or the Child Protection Team.
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6. Working with others
7. Dealing with competitors and suppliers
8. Upholding public trust
Our reputation and the way we are seen as an organisation depends on our relationships with other people, how we learn from them and behave towards them.
Fair treatment
As in our relationship with colleagues, we should treat people outside the British Council with respect as individuals, as well as respecting the behaviours, culture and customs of the countries and territories where we’re working.
Competing fairly
Trust is at the heart of everything we do and every one of us has a duty to behave in ways that actively uphold public trust in us and give people confidence in the integrity of the British Council as an organisation.
Creating relationships built on trust
We believe that maintaining relationships is important, so we do not support boycotts of educational or cultural activities.
Our relationships with customers These are the people who are already using our services or may do in future, such as visitors, scholars, candidates, students and their parents. In all our dealings with them – face-to-face, over the telephone, digitally or in print – we should be helpful, quick to respond, polite and efficient.
Our relationships with clients These are the organisations and people who pay for our services and it is important for us to build lasting and successful relationships with them. We should take the time and trouble to understand their needs and provide them with timely and effective service.
Our relationships with partners As we develop the British Council’s activities, working in partnership with other organisations is becoming increasingly significant. We should build trust with our partners through clear and open communications, and by demonstrating integrity. We should demonstrate a commitment to collaborative working through our willingness to share risks as well as opportunities.
The British Council is committed to conducting all its trading activities in a fair, reasonable and transparent manner.
We are working in an increasingly competitive environment and need to compete strongly and successfully. But, however fierce the competition, we should always behave professionally and conduct our business in a way that is ethical, fair and legal, and in line with our Fair Trading Policy.
Being even-handed Our suppliers quite rightly expect to receive decent treatment from the British Council and be measured by their ability to deliver the right products and services, and offer us value for money. To make sure this happens, we must always be fair and transparent in our dealings with them and follow our established procurement procedures, which you’ll find on the intranet. It is the British Council’s responsibility to pay suppliers on time and in accordance with agreed terms of trade. You must not engage relatives as suppliers nor give any endorsements, testimonials or comments on the performance of suppliers, without first getting approval from a senior manager.
Behaving ethically and responsibly
We must never abuse or harm our colleagues, customers, clients, partners, associates or any member of the community, nor exploit them in any way, nor form inappropriate personal or financial relationships. We should also never behave, at work or in public, in a manner which may damage the British Council’s reputation.
9. Confidentiality and information security Being careful with information Managing information and confidentiality is crucial to the way the British Council operates and is viewed in the world at large. This part of the code is in three parts – information about the British Council, information about individual people and information security.
Information about the British Council We are legally obliged to provide information about our activities, operations, policies and staff to the general public on request. Doing this helps us to build trust worldwide, and we are committed to making the maximum amount of information about us readily available at minimum inconvenience and cost. We do, however, have to balance this obligation with the need to protect the British Council’s operational interests and its responsibilities towards partners, the public and our employees. continued…
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You must not disclose any information that is commercially or politically sensitive to anyone outside the British Council, unless a senior manager has instructed you to do so. Such information may only be disclosed to colleagues on ‘a need to know’ basis. If you work for the British Council in the UK or you’re a British citizen working for us abroad, you are also subject to the Official Secrets Act which prohibits the unauthorised sharing or disclosure of sensitive information. If you are unsure about what you can share with others, speak to your line manager or contact the Information and Knowledge Management team.
Information about individual people We treat all private or sensitive information about colleagues, customers, clients, competitors and other business contacts as confidential. You must make yourself aware of our policies and procedures relating to personal information. All personal data, whether sensitive or not, must be treated in accordance with our Privacy Policy and Guidelines. In many cases, we have a legal duty to protect personal data from wrongful disclosure. For further guidance contact your HR Business Partner or the Information and Knowledge Management Team.
Information security We all have a role to play in protecting the information held on our systems and must adhere to the guidance and standards set out in our Data Security Policy. These principles apply whether information is held manually or electronically. Information which is confidential during your employment remains so should you leave the British Council.
10. Looking after our reputation
11. Financial management and accountability
Making public statements
Maintaining the highest standards
Our reputation has grown and been consistently strengthened since our foundation in 1934.
Our success and, to a great extent, our reputation depend on sound financial management. We have established standards and systems in place to support this and these must always be adhered to.
It’s vitally important to us. So when we’re making statements to the media or British Council contacts, we should always aim to maintain and enhance it. We must never make statements, on or off the record, about politics or on any subject which may damage our reputation or cause a loss of confidence in the organisation. This applies whether we’re making comments about the British Council itself or our colleagues.
Being sensible online Many of us make personal use of the internet, email, websites and social media, such as blogs, microblogs, Facebook, YouTube and Twitter. However, when we’re online and have clearly identified our association with the British Council by discussing our work, using our British Council email address or other means, we should always behave appropriately and in line with our values. We must not reveal confidential information about the British Council, its people or activities nor disclose any information that might bring it into disrepute or prompt a conflict of interest. We should never make offensive comments about people; this could be seen as ‘cyber-bullying’ and would be a disciplinary offence.
The British Council has a duty to make proper use of the funds we receive, as defined in our Use of Public Funds Policy, which can be found on the Finance intranet. In particular, money from the UK government grant must be used only for the purposes for which it is intended. All financial transactions and records are subject to regular scrutiny by the National Audit Office and are open to public comment.
Knowing what’s required of us In all our financial transactions, we must follow the guidance set out on the Finance intranet site. If you’re a manager, you must make sure that you understand the guidance and ensure that it is clearly understood and followed by your team.
Keeping accurate records Any accounting records you keep or contribute to must give a complete and accurate picture of the transactions they relate to.
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12. Property and assets Protecting what’s ours We are all responsible for the British Council’s property and assets, and should take all reasonable measures to protect them from loss or damage. In addition, we should take security precautions against other, less routine risks, such as fire, flood, adverse weather and terrorism. Copyright and similar proprietary rights should also be protected. Corporate standards for the management of documents and records, whether hard copy or electronic, must be followed. For further information, please refer to our Records Management Policy on the intranet.
13. IT and telecommunications Using our systems Everyone who uses the British Council’s IT and telecommunications equipment and systems must adhere to the standards set out in our Acceptable Use of IT Systems Policy. These include controlling access and avoiding inappropriate use of the British Council’s hardware, software, internet and email.
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14. Using funds and resources
15. Gifts, entertainment and payments
Putting our resources to good use
Avoiding unethical rewards and inducements
To protect our reputation and make the best use of our funds and resources, it is important to be clear about how they should and shouldn’t be used. For instance, our funds, resources and the British Council name should never be used to pursue any personal or private matter or interest. We may not use British Council equipment, materials, computer systems or other resources for any outside activity without first getting permission from our country director or senior manager. This also applies to the use of our resources by partners, relatives and friends. It is OK to make occasional use of the telephone, internet and email for essential private and domestic matters, although in some situations you may be required to repay the costs.
In going about our business, the British Council does not seek advantage by giving or accepting any improper gifts, entertainment or payments, and nor must we do so as individuals. We do not accept any level of corruption. We should always be sure that our conduct is ethical, would be justifiable under scrutiny from the press, the public or competitors, and can stand up to examination by those we are accountable to.
No gifts, services or official honours When dealing with existing or potential contacts on behalf of the British Council, we must never give or accept any gift or service which has financial value or could be viewed as a reward or inducement for business. Before you accept an official honour from an overseas government, you must seek prior approval from your senior manager. A gift may be accepted if it has only a nominal value, is a genuine token of thanks and is declared to your line manager. Where you have reason to think that a polite refusal may cause offence or damage the British Council’s interests, you should consult the Gifts and Hospitality Policy.
No excessive entertainment or hospitality In similar vein, while it is acceptable to offer and receive a reasonable level of entertainment and hospitality, this must never be seen to be excessive. Any hospitality you provide must be justified in operational terms. It should be modest, and conventional. In particular it should meet the standards set out in the Gifts and Hospitality Policy.
No payments to political parties The British Council does not make donations, directly or indirectly, to political parties or their representatives; nor must we when acting on its behalf. However, as individuals, we are free to do so.
No other payments without consultation Depending on where in the world we are working, we may find ourselves in a situation where these principles are in conflict with local business practices, for example on facilitation payments. This is a difficult area and the following guidance is designed to help British Council employees at all levels to deal with this dilemma. We must always behave with honesty and integrity when dealing with business contacts and public officials, and must not offer or give them inducements, tips or payments. Only country directors and senior managers may use their discretion on local business practices, and should ensure that any payments made stand up to scrutiny, are legal and in line with our values. Once more, if there is any doubt, country directors and senior managers must ask for a second opinion from a more senior colleague.
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17. Duty of disclosure
16. Conflicts of interest Separating the personal from the professional To maintain our standards of integrity, it is important to avoid any activities that are in conflict or competition with the British Council’s business or are, in some other way, prejudicial to its interests. We should not use our position in the British Council for personal advantage or gain. If you think that there may be a potential conflict of interest, you should follow the guidance set out below.
Outside business interests For example, if you run your own business, hold directorships or trusteeships, or have any interests in the businesses of existing or potential British Council clients, competitors or suppliers, you should inform your country director or senior manager in writing. This also applies to any other organisation where a conflict of interest may arise. If the British Council feels that there is a conflict, it may ask you to give up your post or interest, or restrict your involvement on the British Council’s behalf. The business interests of family members may also create conflicts and you should ask the advice of your country director or senior manager if you think that this might be the case.
Outside employment If you want to take up any paid employment, consultancy or other freelance work outside the British Council, you must first check with your country director or senior manager to make sure that there’s no objection. Permission will usually be given unless the work is likely to create a conflict of interest or might adversely affect your ability to carry out your British Council work effectively.
Other outside activities
Telling us what we need to know
Generally speaking, the British Council encourages outside activities and wouldn’t want to interfere with them.
As well as disclosing any outside activities which may be in conflict with the British Council’s interests (see principle 16 above), we also have a duty to disclose the following.
Playing an active role in the community, for instance, helps employees experience a wider world. But we should avoid any activities that may damage the British Council or reflect badly on it and, when expressing views about public or political issues in speech or writing, we should make it clear that these are our own views and not those of the British Council. You should also think carefully before taking an active part in party politics. If it’s at a national level, you must ask for the agreement of your country director or senior manager, giving details of your involvement. If you are active in politics at a local level, you don’t need to ask for approval unless you think there’s a risk that your involvement may damage the British Council’s interests.
Bankruptcy If you’re declared bankrupt, you must report it to your country director or senior manager and you may be asked to give details of the case.
Legal proceedings If you’re involved in legal proceedings or have any criminal convictions that may affect your suitability for certain posts (working with children and young people, for example), or which may discredit the British Council or bring it adverse publicity, you must report these, too – and again, you may be asked to give details.
Other situations You may find yourself in another situation where non-disclosure might prejudice the British Council’s interests. If you think that this might be the case or you’re unsure, talk to your country director, senior manager or Human Resources Business Partner.
Confidentiality All disclosures will be treated in confidence by your country director or senior manager, who will only share information on ‘a need to know’ basis and will consult Human Resources if in any doubt about how to deal with the information you’ve disclosed.
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18. P ersonal relationships at work
19. Recruiting relatives and friends
20. Dealing with wrongdoing
Being professional about relationships
Giving everyone the same opportunities
Speaking-up
When people form close personal relationships at work it is not usually the business of the British Council to interfere with them. However, our conduct and performance at work should not be adversely affected by such relationships with colleagues, consultants or suppliers. To avoid bias and conflicts of interest, we should not work in the immediate management line as colleagues who are partners or relatives. If you do have a close personal relationship with a colleague working in the same department, you should let your manager know. Similarly, if you are a manager and have a personal relationship with someone who reports to you, you should tell your senior manager. Where this is the case, the information must be treated in confidence. The same principle applies if you have a close personal relationship with a consultant or supplier and you are in a position to decide on the awarding of work, purchasing or contracts. You must let your manager know and you may be asked to change your role or responsibilities.
If you receive an application for employment, internally or externally, from your partner or a relative, you must inform your manager and ask to be removed from the recruitment process. This is to make sure that everyone has equal employment opportunities. If you receive an application from a friend, you must ask for the agreement of your country director or senior manager before any appointment or job offer is made. Agreement will usually be given so long as the appointment does not compromise the integrity and independence of the financial or other management control systems in place in the office or workgroup concerned. If your partner, relative or friend is recruited, these control systems may need to be altered to make sure that the necessary separation of duties is maintained.
The British Council is committed to upholding the highest ethical and legal standards and has zero tolerance for malpractice or wrongdoing anywhere in the organisation. To help us deal with this, we want people to feel that they can speak-up and raise concerns about wrongdoing confidentially, and our Speaking-up Policy enables us to do this. Examples of malpractice or wrongdoing include child abuse, theft, fraud, false accounting, misuse of assets, receiving bribes, failing to disclose outside business interests, and breaches of regulatory requirements, as well as breaches of this code of conduct and other British Council policies.
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The process If you become aware of, or suspect, any serious wrongdoing, you must report it as soon as possible to your own manager or someone else in your management line. Do not confront the suspected perpetrator, discuss the case with colleagues or people outside the British Council, or try to conduct your own investigations. If you feel unable to discuss the matter with your line manager or you still have concerns, you should contact the Head of Internal Audit or the Global Human Resources Director. If the matter is so serious that you feel you cannot raise it with them, you should contact the British Council board member named on the Internal Audit intranet site, which also contains further guidance about how to deal with this difficult issue. Please note: if you ask for your identity to be protected, it will not be disclosed without your consent unless in response to a legal requirement. Concerns should not be raised to pursue private disputes and malicious false allegations will be regarded as a disciplinary matter.
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Investigating breaches of our code We hope that you’ll appreciate that this code is in everyone’s interests and will familiarise yourself with it, refer to it and follow it. Please be aware that breaches of the code can lead to action under the disciplinary procedure applicable in your office (Human Resources can advise you about this), and that all breaches will be investigated before formal disciplinary action is taken. Investigations take account of all the relevant circumstances, including the seriousness of the breach and whether adequate guidance has been given to the people concerned.
Further sources of information To find out more about the British Council’s policies and other subjects covered by this code, please consult the following pages on the intranet: Acceptable use of IT systems Child Protection Data Protection Equal Opportunities Essential Finance Fair Trading Finance Policies Gifts and Hospitality Global Security Policy Health and Safety HR Policies Information Risks Internal Audit Managing Risk These policies are updated from time to time. Thank you for taking the time to read this code.
All photography © Mat Wright © British Council 2013 / C492 The British Council is the United Kingdom’s international organisation for cultural relations and educational opportunities.