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
1
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
Our Code of Conduct
2
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
Our Code of Conduct
3
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.
Our Code of Conduct
4
Our
Code of
Conduct
Our Code of Conduct
5
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.
Our Code of Conduct
6
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.
Our Code of Conduct
7
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…
Our Code of Conduct
8
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.
Our Code of Conduct
9
Our Code of Conduct
10
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.
Our Code of Conduct
11
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.
Our Code of Conduct
12
Our Code of Conduct
13
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.
Our Code of Conduct
14
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.
Our Code of Conduct
15
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.
Our Code of Conduct
16
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.