B) Code of Conduct

B1) Background

Courses at The English Language Centre are primarily aimed at adults aged 18 and above but we do welcome students aged 16 and 17. Our students come from a wide range of ages, cultures, religions and backgrounds. ELC exists to give all our students the best teaching and learning facilities we can. We are committed to providing students with excellent courses in a warm, friendly and professional environment, as well as caring for every aspect of their stay. We understand the importance of our staff in creating such a professional environment and we are committed to their care, training and support. ELC also recognises that it has a responsibility to provide a safe and healthy learning environment for all students and staff built on mutual trust but especially for students under the age of 18 and vulnerable adults. The need for and benefits of this Code of Conduct are explained during both the staff and student induction process.

Purpose, Scope and Principles

The aims of this Code of Conduct are:

  • to both support and protect students and staff
  • to set boundaries, standards and give clear guidelines on what is expected of ELC staff in order to help create the warm, friendly and professional environment we aspire to, both in general and with specific reference to under-18s and vulnerable adults

This Code of Conduct applies to all staff who are employed by the organisation including volunteers and work experience staff. All staff have a key role to play in defining how we are as an organisation and how we are perceived by our colleagues, students, clients and all other stakeholders. In addition to our academic and care commitments to students and staff, we aim:

  • to actively promote inter-cultural understanding
  • to encourage appreciation of the different ways we all live, think and learn
  • to treat everyone with respect and dignity

As such, whilst maintaining the identity we wish to have and complying with our statutory and legal obligations, we should be sensitive to different cultural backgrounds and expected behaviours.

Even if it were desirable, it would be impossible to write up an exhaustive list of rules prescribing staff behaviour. However, whilst we trust staff to make professional and common sense decisions, we have provided clear guidance on certain issues. As a general guideline we would expect students to be treated in the way that we would wish our own friends, colleagues and family members to be treated in a foreign environment in which they are likely to be more vulnerable and lacking in awareness of the surrounding environment, language and cultural norms. If you are ever not sure about the appropriateness of your behaviour, think about whether you would be happy for it to be transparent and if you have any questions or doubts about points in this Code of Conduct, or matters not covered here, please speak to your line manager for guidance.

Under 18s (and vulnerable adults)

Separate Child Protection Policies and Procedures have been developed and are available on our website, from line managers and provided as part of training. In considering the vulnerability of adults, age is not necessarily the determining factor. It could be said that anyone of any age with a limited level of English in the UK for the first time is vulnerable so some of the following may equally be relevant to 18+.

This section of the Code of Conduct is written to give clear and formalised guidance to school staff on creating a safe school culture for under 18s. This includes protecting both adults and students under 18 from behaviours or actions that might be misconstrued, and to ensure that staff do everything reasonable in their power to ensure the safety and wellbeing of under 18s studying at the school.

B2) Child protection – posistion of trust

We have a legal and moral duty to protect our students from the risk of sexual, physical and emotional abuse, and neglect. Any sexual activity between an adult who has a position of care and responsibility in the school (including temporary summer staff) and an under 18 year old is illegal even though the legal age of consent is 16 (Sexual Offences Act 2003). This also includes non-contact activities such as causing students to watch sexual activity.

B3) Setting standards

In all we do, the yardstick we will use is that of adopting behaviours that we would expect a responsible parent to adopt, and treating students under the age of 18 in the way we would wish our own family members under the age of 18 to be treated in a foreign environment in which they are likely to be more vulnerable and lacking in awareness of the surrounding environment, language and cultural norms. Young people will look up to staff and look to them for clues about how to behave in a new environment: hence it is important that staff consider this in their behaviour and provide a suitable role model for them. This might include how they talk to others, which subjects are appropriate to talk (or joke) about, and how they dress and the way this might be read by younger students.

B4) Interaction with under 18s

The school expects staff to behave with common sense to ensure the safety and wellbeing of young people under the age of 18. To ensure ease of identification, students under 18 are required to wear an ELC wristband during the busy summer course. Students under 18 will also be clearly identified on class lists where they are participating in adult courses. They will also be identified in out of school activities and under 18 reports will have photos of the students. For the purposes of this code of conduct, here are a few particular areas to consider:

  1. Staff should avoid situations where they are left alone in an enclosed space with an under18. If a confidential meeting is necessary, it should be undertaken with a door open close to other staff or adults and if appropriate tell a colleague that a 1:1 meeting with an under 18 is taking place.
  2. Staff should take extra care with the language that they use around under 18s, making sure that it is always appropriate to their role.
  3. In all instances staff should avoid favoritism and be as positive and even-handed with under 18s as possible, using praise where appropriate and ensuring that all of the students are treated equally and fairly.
  4. Staff should as far as possible avoid any physical contact with students under the age of 18, particularly contact which might be misconstrued by the under 18 or by someone else witnessing it. Clearly physical chastisement is illegal and any incidence of a member of staff using physical chastisement would result in dismissal and the police being informed. If it is necessary to touch a student, for example in a first aid situation, explain what you’re going to do and why and ask permission first.
  5. Staff should be especially careful in any dealings with under 18s they might have in a social setting outside of the school. These might easily be misconstrued by the under 18 year old(s) or by others. If you do meet students outside school, make sure that it’s as part of a group and never with a single under 18 student.
  6. Staff should neither explicitly nor implicitly condone the breaking of the law, particularly in regard to drinking alcohol, taking drugs, smoking, sexual activity or extremist views/behaviour. Any concerns in this area should be reported immediately to the Principal.
  7. On excursions and activities organised by the school, due regard should be given to the risk assessment document and in particular to any special measures adopted for under 18s on that trip. In general, it should always be ensured that under 18s are with at least 2 other people at all times, and, if necessary, with the member of staff leading the trip.

Under 18s (and vulnerable adults)

We understand that personal relationships may develop at work: with colleagues, clients, students or people that you may meet whilst on ELC business. Such relationships need to be handled sensitively. Particular issues can arise when the two parties are of different seniority levels or working within the same area. Resentments can arise if it is felt that an individual is being treated differently, and if a relationship should end it can be difficult for the two parties to continue working with each other.

It is essential that there is a harmonious and professional atmosphere amongst the staff at all times. You are expected to ensure that any personal relationships do not interfere with this. Personal relationships between members of staff are, in the end, a private matter, however in order to avoid misunderstandings and potential problems, it would be a courtesy to inform your line manager and you are encouraged to do so.

In the same way, you are expected to behave positively and with professionalism in your dealings with colleagues even if you do not get on with them personally.

Personal relations with students and clients are a particularly sensitive area. Although most people studying here are adults, you must at all times remember that you may not be regarded as having equal status even if that is your perception. This will apply with particular force if you are a teacher and the individual concerned is in your class. While normal social friendliness is certainly encouraged, staff are expected to be professional and maintain clear boundaries while at work or taking part in the social programme. Intimate relationships are often inappropriate and if you perceive that one is developing you are urged to discuss this with your manager or with another senior member of staff.

It is not uncommon for young students to develop a ‘crush’ or infatuation on a member of staff. Staff should therefore make every effort to ensure that their own behaviour cannot be brought into question and does not appear to encourage it. Any member of staff that becomes aware that a young person has become or may be becoming infatuated with either themselves or a colleague should immediately report this to the Principal or Vice Principal. In this way appropriate early intervention can be taken which can prevent escalation and avoid hurt, embarrassment or distress for those concerned.

Under no circumstances would an intimate relationship between an adult member of staff and a student, co-worker or volunteer in the school under the age of 18 be appropriate. If it becomes apparent that one has developed, it would be seen as a serious breach of the school’s policy in this area and will lead to immediate dismissal and a report about the individual adult being made to the DBS. Any sexual activity between an adult who has a position of care and responsibility in the school (including temporary summer staff) and an under 18 year old is illegal even though the legal age of consent is 16 (Sexual Offences Act 2003). It is also illegal to cause students to watch sexual activity.

Harassment and bullying

In order to achieve a safe, warm, friendly and professional environment for students and members of staff ELC is committed to ensuring that everyone is able to work and to participate in the life of the school without fear of harassment, bullying or intimidation. Everyone at ELC has a part to play by ensuring that their own behaviour, whether intentional or unintentional, does not constitute harassment. ELC will take action against inappropriate behaviour which shows lack of respect for others or which leads people to feel threatened (see Policy on Bullying and Harassment).

Socialising with students and clients outside of work

It is part of the nature of our industry that staff, and particularly teaching staff, social organisers and guides, may socialise with students and clients outside of the school setting. In some cases this may be an organised ELC activity. In other cases it may be an informal gathering of, say, a teacher and their main class, or lunch/dinner with a client as part of a marketing event. In all cases, these will be perceived as an ELC event and as such staff should represent ELC in a professional manner and neither explicitly nor implicitly condone the breaking of the law, particularly in regard to drinking alcohol, taking drugs, smoking, sexual activity or extremist views/behaviour. Please see above for guidance with regards to interaction with under-18s.

B5) Dress Code

The way that staff dress can have an effect on many students and some can find it difficult to respect them or their role if they don’t present themselves appropriately. Staff are therefore expected to be of clean appearance, and smartly dressed in a way that is appropriate for the situation in which they are working and to present a professional image that reflects sensitivity to customer perceptions. Shorts and beach sandals/flip flops are not normally appropriate. Jeans and trainers should be smart. Clothes should not be frayed, ripped or have holes in them. Thin strapped vest tops, off the shoulder and strapless tops would not be appropriate neither would clothing with inappropriate wording or slogans.

B6) Misuse of drugs and alcohol

It would be considered a disciplinary offence for staff or students to be on ELC premises and/or, in the case of staff, carrying out official duties when under the influence of alcohol or non-medically prescribed drugs.

Staff should neither explicitly nor implicitly condone the breaking of the law, particularly in regard to drinking alcohol, smoking, sexual activity or taking drugs. It is better to educate Under 18s about addictive substances than to make light or joke about them. Any concerns in this area should be reported immediately to the school’s DSL or the Principal.

B7) IT, the Internet, social networks and other technology

While access to the internet and phones are wonderful ways for young people to stay in touch with their friends and family, they also provide opportunities for abuse and inappropriate behaviour. In particular, there are risks to young people through cyber bullying (possibly by their peers), exposure to radical/extremist views, grooming by adult sexual predators, and downloading of illegal or copyrighted materials and possibly computer viruses. The school has therefore established the following guidelines:

  1. Staff should not give out their personal mobile number, email address or Facebook contact details to students, especially those under 18. If a member of staff is carrying out ELC business – for example, taking a group of students out of school and for safety concerns they need to give the students a contact number, they should borrow the DOSs school phone if possible and give them the number (it is in their blue folders in the Attendance section) or make sure that they all have the school emergency number (on their student cards and in Attendance section of their blue folders). ELC can provide official email addresses for staff, to receive homework for example. If a ‘closed app group’ is created for academic purposes, please advise your line manager and copy him/her into the group too.
  2. Inappropriate access to websites should be reported to the Principal. Inappropriate websites include pornographic sites, excessively violent videos and games, websites promoting extremist/terrorist views and some age inappropriate social networks and chat rooms. Most inappropriate sites are blocked on the school network, but may be accessed by students in a home setting or possibly by bypassing safeguards. Therefore, all staff are asked to be especially vigilant regarding use of the internet by under 18 year olds, and if there are concerns about content, excessive use or possible grooming or abuse, they should be reported and/or action taken to remove access.
  3. All students are made aware of the school’s IT policies at induction and these are displayed prominently in the school and in particular in the computer rooms.
  4. Staff should never use their own photographic equipment (including mobile phones) to take images of students. If they plan to film or take photos of any under 18s on school equipment, they need to make sure that the student is happy for them to do so and check with the office that the parents have given their consent. Any images should be deleted immediately after use.
  5. Both staff and other students should be on the lookout for signs of cyber bullying as it can happen to anyone – it is so insidious as it is often anonymous and can happen 24/7. Signs to look out for include noticing if a student is especially quiet and withdrawn.

Publicity and digital content

In addition to our websites, brochures and promotional materials, digital media has a much greater impact on how the organisation is perceived and can have a significant impact on how a potential client or current stakeholders (eg parents, sponsors) regard us. Although we actively encourage digital content (YouTube, Facebook, Twitter, Instagram), it is essential that these serve only to enhance the school’s reputation with high standards of content and presentation. We also request that any such content that represents the school should be approved by a line manager and use official ELC channels.

B8) Accommodation specific Issues

In addition to the above guidelines, homestay providers should be aware of the following areas:

  1. Respecting the privacy of the individual in their room (including from other children and pets who may live in the household), and in particular always knock and attempt to gain permission to enter the room before entering a bedroom or bathroom.
  2. Not allowing adults to be alone in a bedroom or bathroom with a child unless the door is open and other adults are present in the house. Adults should meet under 18s in communal rooms whenever possible.
  3. Being appropriately dressed around the house.

B9) Transport

All contractors working for the school to transport children will provide annual written evidence that their staff have been properly DBS checked.

If for any reason a member of staff is required to transport a child in your car:

  • Ensure seatbelts are used.
  • If you are dropping off children after an event, try to keep a pair of students at the same address as your last drop off: avoid being alone in a car with a child as far as possible but if it is unavoidable, make sure that they sit in the back.
  • Ensure you have appropriate insurance cover.

Prevent (radicalisation and extremism) Policy

  • ELC is a multicultural and international community that actively promotes inter-cultural understanding and encourages an appreciation of the different ways we all live, think and learn. We will endeavour to educate students about acceptance and tolerance of a range of views, that people think differently and believe different things, all of which are acceptable as long as these views and beliefs are reasonable and do not extend to hurting or denigrating those with different beliefs.

While this is unlikely at ELC, if anyone in the school suspects that someone is expressing views that might hurt or denigrate those with different beliefs, this should be brought to the Vice Principal’s attention so that any action can be considered. This is particularly important if it appears that this person is attempting to radicalise other students with these views.

Also, in order to help us comply with our Prevent duties, staff are expected to:

  • Promote a safe and supportive international environment via clear expectations of accepted behaviours and those, including radicalisation and extremism, that will not be tolerated.
  • Exemplify core British values (democracy, the rule of law, individual liberty, respectful tolerance of different faiths or beliefs) in their management, teaching and through their general behaviour, including through opportunities in the curriculum. The approach is to educate that this is how things are in UK; although it may be different to the student’s country of origin.
  • Where possible, develop critical awareness and thought to counter accepting extremism without question, especially of online material.
  • Challenge radical or extremist views in any context (formal or informal) via stated procedures.

B10) Informing management if you have concerns about a colleague’s inappropriate behaviour (Whistleblowing)

Staff are obliged to inform management of any concerns about colleagues not following this Code of Conduct in the knowledge that they will not be penalised as a result and that their report will remain confidential. The NSPCC Whistleblowing helpline is 0800 028 0285. (This number is displayed in both offices and teachers’ rooms

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