CodeOfConduct Updated

8/18/2019 CodeOfConduct Updated

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www.britishcouncil.org

TRUST IS NOT GIVEN.IT’S EARNED

OURCODE OFCONDUCT


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CONTENTSFOREWORD 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....................................................... 78. 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. Using 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


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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 aboutwho 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 publicservice 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

HOW WEBEHAVESAYS WHO

WE ARE

OUR CODE OF CONDUCT

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OUR CODE OF CONDUCT

Our values underpineverything 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:

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OURVALUES

Valuing people

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 unlockpotential and help people be the best

they can be.

Integrity

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 andthey learn from us, all with a view to

advancing the creation of global citizens.

Creativity

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.

Professionalism

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.


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Circumstances may change,but our principles don’t

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.

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.

These principles are hereto help us

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 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 ChiefExecutive 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.

OUR CODE OF CONDUCT

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INTRODUCTION

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OURCODE OFCONDUCT

OUR CODE OF CONDUCT

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1. Legal compliance

Respecting the lawWe 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.

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.

3. Equal opportunities

Avoiding discriminationThe 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, socio-

economic background, spent convictions,

trade union activity or membership, work

pattern or any other such grounds.

The principles which underlie our Equal

Opportunities Policy apply worldwide andmust 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.

4. Health and safety

Looking after peopleAs 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.

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 childrenWe 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

Creating relationships built on trustOur 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.

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.

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 isimportant 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.

7. Dealing with competitorsand suppliers

Fair treatment

The British Council is committed to

conducting all its trading activities in a

fair, reasonable and transparent manner.

Competing fairly

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 topay 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.

8. Upholding public trust

Behaving ethically and responsiblyTrust 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.

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 andinformation 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 andits 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 Off icial

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 afterour reputation

Making public statements

Our reputation has grown and been

consistently strengthened since our

foundation in 1934.

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 whetherwe’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.

11. Financial managementand accountability

Maintaining the highest standards

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.

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 oursWe 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 andtelecommunications

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 fundsand resources

Putting our resources to good use

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 countrydirector 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.

15. Gifts, entertainmentand payments

Avoiding unethical rewards and

inducements

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 off icial 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 tokenof 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 tooffer 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 dif ficult 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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OUR CODE OF CONDUCT

16. Conflicts of interest

Separating the personal fromthe 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 activitiesGenerally speaking, the British Council

encourages outside activities and

wouldn’t want to interfere with them.

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.

17. Duty of disclosure

Telling us what we need to knowAs 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.

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 HumanResources 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. Personal relationshipsat work

Being professional about relationships

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 samedepartment, 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.

19. Recruiting relativesand friends

Giving everyone the same

opportunities

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.

20. Dealing withwrongdoing

Speaking-up

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, falseaccounting, 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 HumanResources 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 falseallegations will be regarded as a

disciplinary matter.

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INVESTIGATINGBREACHES OFOUR CODE

We hope that you’ll appreciate that this

code is in everyone’s interests and will

familiarise yourself with it, refer to itand 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.

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Further sources of information

To find out more about the British Council’s

policies and other subjects covered by thiscode, 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.

Documents

CodeOfConduct Updated