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. 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.

While 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 a respectful and understanding way 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 (eg a member of staff) and an under 18 year old is illegal (Sexual Offences Act 2003). This also includes non-contact activities such as causing students to watch sexual activity.

B3) Setting standards

Staff should always put the well-being of our students first as our students may be 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. 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. the following considerations must be taken into account: -

  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 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 favouritism 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. 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 both in and outside the school environment as their actions 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. This includes drinking alcohol, taking drugs, smoking, sexual activity or extremist views/behaviour. Any concerns in this area should be reported immediately to the DDSL (Director).
  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.

If students under 18 are taking part in an activity, then members of staff are not allowed to drink any alcohol at all. If no students under 18 are present at an ELC activity, staff are allowed to consume alcohol but only in moderation. Staff are not to meet students off site outside of school time. If they do meet them by chance, they should leave that venue.

Under 18s (and vulnerable adults)

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 always inappropriate and if you perceive that one is developing you must discuss this with the DSL (Director).

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, positive, 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 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, including drinking alcohol, taking drugs, smoking, sexual activity or demonstrating 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. 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) Acceptable use of IT 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 Vice Principal's 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. ELC is part of the Clifton College Education group and inappropriate use of the College internet is blocked and flagged to the College Safeguarding Coordinator who then notifies ELC's DSL (Director) who will take appropriate action. Inappropriate websites include pornographic sites, sites promoting the use of drugs, excessively violent videos and games, websites promoting extremist/terrorist views and some age inappropriate social networks and chat rooms. Inappropriate sites might still be accessed by students in a home setting or possibly by bypassing safeguards. Therefore, staff are asked to be vigilant especially 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 must report this to the DSL.
  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 student 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.

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 Clifton College's Headmaster 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).

B11) ELC Bristol and access to Clifton College

• ELC staff must wear a blue lanyard all the time both within the ELC school building and within the Clifton College campus. They must also wear a lanyard if attending an event on the College site.

• In exceptional circumstances, ELC may start a new member of staff who has not been fulled onboarded provided he/she is wearing a red visitor lanyard and provided the situation has been risk assessed and signed off by the College's Safeguarding Director. Staff wearing a red lanyard can only access the college site provided they are accompanied by a fully onboarded member of staff wearing a blue lanyard. Once they have been onboarded they will be given a blue lanyard which they must wear at all times.

• With a blue lanyard, staff can access the full Clifton College site. If they only have a red lanyard, they must be accompanied by a member of staff with a blue lanyard at all times, including when going for lunch.

• For safeguarding reasons, ELC students have no access to the College site. For this reason, they do not have to wear lanyards. Their only access is to the College Sports Centre (Gym and Swimming Pool) which they can access at designated times.

• To use the sports facilities, ELC students must first pay for a sports pass, for which there is a one-off cost of £10.00. The sports pass will only be given to the students if they can prove they are ELC students by showing the ELC student card to the Sports Centre staff.

• If students want to buy an ELC t-shirt, they can buy these from the sports centre. If they want to buy something from the school shop, they must wear a red lanyard and be accompanied by a member of ELC staff with a blue lanyard. This usually happens on Friday afternoons.

• For students to walk from the main school building at 1 the Avenue to 4-5 Worcester Road (our summer centre), they cannot cut across the campus but must walk via Pembroke Road (5 minutes).

• Visitors to ELC must wear a red lanyard and must be signed in by a specified member of staff who has a blue lanyard. Visitors cannot walk freely around the College site but must be accompanied at all times by the person who signed them in.

• When signing in, and before they are given a red lanyard, visitors to ELC are given a flyer outlining appropriate behaviour for an environment where there are students under 18. They must read this flyer before they are given a red lanyard.

• Smoking and vaping. The only place students can smoke or vape is in the school garden. They are not permitted to smoke or vape within 3 metres of the front door or in the road between the school and the College.