Employee Code of Conduct

Code of Conduct Policy

1. Introduction

1.1 Why you must read our Code of Conduct

Cotswold District Council expects every employee to behave in a highly professional manner. That’s
why you need to read and understand the Code of Conduct as it sets out the standards, we expect
from you while you are at work.

1.2 What is the Code of Conduct?

The Code of Conduct is designed to provide guidance about what is expected from you in your daily
work and in your dealings with elected members, colleagues, and the public.
As an employee of the Council you must be familiar with the Code of Conduct. This document
forms part of your contract of employment and you are required to comply with its contents. Failure
to do so may result in disciplinary action, up to and including dismissal.
For this reason, it is important that you read the whole of this document and ask your manager or
Human Resources (HR) for clarification if there is anything in it that you don’t understand and needs
explaining.
Once you have signed and returned the acceptance section, it will be assumed that you understand
its contents, agree to comply with your contract of employment, and all the rules and policies, etc
that it refers to.

1.3 Who does it apply to?

The Code applies to all employees’ and anyone acting as an employee of the Council (to clarify - the
use of the word ‘employee’ within this code includes permanent and temporary employees, casual
workers, and agency staff).
Inevitably, some of the issues covered will affect some employees more than others. Although the
Code does not directly apply to contractors, consultants or volunteers, the Council’s continued
association with these individuals and/or their organisations requires them to observe and comply
with the Code. However, in some instances, compliance may be a condition of the contract between
a third party and the Council, in which case their compliance with the Code would be binding.

1.4 Other Policies and Procedures

The various sections of the Code of Conduct summarise key Company policies and procedures in
respect of behaviour and the ways in which you are required to work. If you are in any doubt about
how they apply to you, you should always refer to the full policies and procedures. These can be
accessed via the Council Portal, requested from your line manager or through the Council’s HR team
at HR@publicagroup.uk.

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Acceptance Form

Once you have read and understood this Code of Conduct, please complete the form below
and return this to HR@publicagroup.uk.

Please remember it is important that you read the whole of this document and ask your
manager or HR for clarification if there is anything in it that you don’t understand and needs
explaining. Once you have signed and returned the acceptance section, it will be assumed
that you understand its contents and agree to comply with your contract of employment and
all the rules and policies, etc that it refers to.

I have read and understood the Cotswold District Council Code of Conduct.

Name

…………………………………………………………………………………………………

Signature

…………………………………………………………………………………………………

Job Title

…………………………………………………………………………………………………

Date Your Manager:

………………………………………… …………………………………………

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2. Standards of Behaviour
The sections below, together with the seven principles which are set out in Section 28 of the
Localism Act 2011, and which were originally set out by the Nolan Committee on Standards in Public
Life contained in Annex A, set out the framework within which all employees must operate. Failure
to do so may result in disciplinary action, including and up to dismissal.

2.1 Workplace behaviour and personal conduct

In summary, you are required to:

 Act with dignity and treat all others, including colleagues, elected members and members of the
public with dignity and respect.
 Ensure your behaviour and performance meets workplace standards at any time that you are
representing the council or are likely to be identified or associated with your role as a public
official (whether or not you are ‘on duty’ at the time).
 Ensure you are familiar with and follow the council’s rules, policies and procedures
 Be committed to delivering quality services to service users
 Work in accordance with the terms and conditions of your contract of employment and job
description

2.2 Grievances

The Council encourages a culture in which you can raise any workplace problems, complaints, or
concerns in a supportive framework. If you have a concern or grievance, you can use the Grievance
Policy.

Most issues can be resolved informally, however, if an informal approach does not resolve matters,
or is not appropriate, you may choose to raise a formal grievance.

Any employee who submits a grievance in good faith will not suffer any adverse consequences as a
result of submitting the grievance. Should your allegation be found to be vexatious or a complaint
which is falsely made; that is, it is not made in good faith or based on evidence, this may result in
disciplinary action.

2.3 Reporting Absence

If you are unable to attend work for any reason, preferably, you should notify your manager of non-
attendance by telephone before you are due to start work or as soon as reasonably practicable,
providing your reason for absence to enable your manager to make alternative arrangements for
your work to be covered if required.

If your manager is unavailable, you should contact the next most appropriate manager.

Notification of sickness absence should preferably be via telephone, rather than text message, email,
or social media. In exceptional circumstances, where the employee is unable to telephone (for
example, because of hospitalisation), another person such as a friend or relative can contact the
Council on their behalf.

Please refer to the Sickness Absence Policy for more information.

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2.4 Misconduct

The Code of Conduct guides and assists employees acting in good faith. If, in your decisions, actions
or conduct, you wilfully fail to comply with the standards outlined in the Code of Conduct, you will
be guilty of misconduct and are likely to fall subject to disciplinary action, up to and including
dismissal.

2.5 Learning and Development

As part of your employment with the Council you are obliged to participate in and complete a range
of mandatory learning and development courses, including, but not limited to those found on your
iHasco homepage.

You may also be required to participate in learning and development to develop your skills and
knowledge to perform your job and improve the service we deliver as a Council and the
communities we serve.

You are required to participate in an annual appraisal and performance review and reasonably engage
in any plans for improving your work performance. If you are a manager, you are required to
complete an annual appraisal for your direct reports.

2.6 Alcohol and Drugs

As an employee of the Council, you must not consume alcohol, use illicit drugs/legal highs or other
illegal substances while at work and must not attend work under the influence of such substances.

There are times when you may attend a work event, such as an awards night, where alcohol is
available. At these times, alcohol may be consumed with permission, however, you must remember
that you continue to represent the Council.

The Council reserves the right to undertake a programme of random alcohol and drug testing.

Similarly, if you are taking legally prescribed or over-the-counter drugs, you must ensure that their
use does not adversely affect your work performance and the safety of yourself and others. If you
are concerned about prescription medicines, please speak to your GP and to your line manager to
discuss any potential side effects.
If you are a manager, you will need to consider the options available for assisting employees who are
required to take legally prescribed drugs and whose level of performance has been impaired. In these
circumstances, a risk assessment should be undertaken with the assistance of the Occupational
Health service.

2.7 Health & Safety

All employees have a personal and legal responsibility under the Health and Safety at Work Act 1974
for themselves, colleagues and visitors to Council buildings and premises.
These responsibilities are outlined in the Health and Safety policy. In summary, your legal duties as an
employee are:

 To take reasonable care for the health and safety of yourself and others who may be affected by
your actions or omissions at work.

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 To co-operate with employers or other persons to enable you to perform your duties or
requirements under the Act.
 To work in accordance with the health and safety training that you have been provided.
 To notify the Business Partner for health and safety in the workplace of any unsafe condition,
hazard, or risk that you identify.

2.8 Equal Employment Opportunity and Workplace Diversity

We believe that a culture of equality, diversity and inclusion not only benefits our organisation but
supports wellbeing and enables our people to work better because they can be themselves and feel
that they belong.

As an employee of the Council, we expect you, and every one of our people, to take personal
responsibility for observing, upholding, promoting, and applying Equality, Diversity, and Inclusion. Our
culture is made in the day-to-day working interactions between us, so creating the right environment
is a responsibility that we all share.

Any dealings that you have with colleagues, or third parties must be free from any form of
discrimination, harassment, victimisation, or bullying.

If any of our people are found to have committed, authorised, or condoned an act of discrimination,
harassment, victimisation or bullying, we will take action against them including (for those to whom it
applies) under our Disciplinary Procedure.

2.9 Employee Appearance

Your dress style must reflect appropriate workplace health, safety, and security considerations
applicable to your job and work environment. If you are attending a meeting with external parties or
presenting a report at a Cabinet or Council meeting that is open to the public or broadcast on the
internet, you should wear smart workplace clothing and avoid wearing attire that might be
considered by an average member of the public to be too casual or too informal for the role you are
fulfilling.

If you are required to wear Personal Protective Equipment (PPE) as part of your job role, you must
ensure that this is worn and in compliance with the relevant Risk Assessment / Safe System of Work.

If you are required to wear a uniform as part of your role, you must ensure that this is worn during
working hours. If you are wearing this uniform outside of the workplace, you should remember that
during this time, you remain recognisable as an employee of the Council and therefore, you must
ensure you comply with this Code of Conduct.

2.10 Driving on behalf of the Council

While driving Council or your own vehicle for work purposes, employees must comply with traffic
legislation, be conscious of road safety and demonstrate safe driving and other good road safety
habits.

You must hold a current driver’s license for the category of the vehicle you are driving and must
upload this into business world on an annual basis. You must also have business cover on your
insurance.

You must notify your line manager or HR if your driving licence has been suspended or cancelled, or
has limitations placed upon it, including any penalty points.
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The following actions while driving on Council business will be viewed as serious breaches of
conduct and may lead to disciplinary action up to and including dismissal:

 Drinking or being under the influence of drugs while driving.

 Driving while disqualified or not correctly licensed.
 Reckless or dangerous driving causing death or injury.
 Failing to stop after a collision.
 Acquiring penalty points leading to suspension of licence.
 Any actions that warrant the suspension of a licence.
 Bringing the Council into disrepute.

Please note that this is not an exhaustive list and will depend on whether you are required to drive
for business purposes.

2.11 Social and Environmental Protection

The Council has declared a climate emergency and is committed to doing our bit to address and help
tackle the challenge of our generation: not only around climate but also the less well publicised
biodiversity crises affecting our planet.

We must consider the environmental impact of the services we deliver and consider ways in which
we can minimise these impacts such as through reducing consumption, waste minimisation, energy
efficiency, technology and through procurement which takes into account the environmental impact
of products and services and supports the purchase of sustainable products.

3. Protecting the Council and our Employees

3.1 Conflicts of interest

A conflict of interest is any activity that is inconsistent with, or opposed to, our Council best
interests or that gives the appearance of in propriety or divided loyalty. You must not place yourself
in a situation within which you could derive or be perceived to derive personal benefit from actions
of decisions made in your official capacity as an employee. This also applies to any perceived or actual
benefit.

Some examples of conflicts (or perceived conflicts) between personal interests and our public duties
as a Council are shown below.

 Employees who have access to computer databases of customers/updating their own personal
records, or those of close relatives.
 Liaising with a supplier who employs one of your close relatives.
 Being contracted to provide services to the Council outside of your paid employment.
 Generating work which involves travel to provide an opportunity to visit friends.
 Involvement with an interview panel when a relationship exists with one of the applicants.
 Involvement in a procurement process where a relationship exists with one of the suppliers.
 If you or a close family member or business partner submit an application for Planning
Permission, Listed Building Consent or similar.

If you are unsure about a personal conflict, talk to your manager or a member of the HR team in the
first instance.

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Additionally, you must not use your position to obtain favourable treatment for any individual with
whom you have a significant relationship, this applies to both friends and family as well as any
individual you may have a contractual relationship with – such as a landlord or employee. If any
employee finds themselves in a position where they are dealing with a business matter which involves
or is likely to involve a family member or other persons with this, they have a significant relationship,
they must take immediate advice from HR, Procurement or their Line Manager. For the avoidance
of doubt nothing in the paragraph is intended to affect the refer a friend scheme.

If you believe you have a potential conflict involving a family member, or other individual, you also
have an obligation to declare it as part of the annual declaration process. Completion of the annual
declaration is mandatory for all employees.

3.2 Dealing with a potential conflict of interest

Line Manager(s) together with HR are required to review any conflicts of interest that are declared
and to determine whether any actions are required to mitigate the conflict. There may be occasions
where the conflict is profound and acute. In such cases it may be necessary to consider a range of
possible actions which may include, but not limited to:

 Deciding that no action is needed.

 Restricting the employee(s) involvement in discussions and excluding them from decision
making.
 Removing the employee(s) from the whole decision-making process.
 Removing the employee(s) responsibility for an area of work.
 Removing the employee(s) from their role altogether if the conflict is so significant that they
are unable to operate effectively in the role.

3.3 Confidential Information

As an employee of the Council, you may obtain, have access to or be responsible for Council
information that has not been made public and is still confidential. You must never disclose
information given in confidence by anyone, or information acquired which you believe is of a
confidential nature, without the consent of a person authorised to give it or unless you are required
to by law.

You must not prevent another person from gaining access to information to which that person is
entitled by law. You must not disclose confidential information for your own personal use or for use
by anyone else known to you, or to the disadvantage or the discredit of the Council or anyone else.
You must always observe the provisions of the Data Protection Act 2018, the Freedom of
Information Act 2000, and the Council procedures for the release of personal information held about
other employees or members of the public. Breach of confidentiality may be considered a disciplinary
offence, which could result in dismissal.
When you leave your employment with the Council, you must still respect the confidentiality of
official information that may have been available to you in the course of your duties and not use this
information for private, commercial or political gain.

3.4 Data Protection

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All employees, whether permanent or temporary, have a responsibility for the protection of data and
are required to adhere to the Data Protection Policy, along with any associated procedures and to
attend any associated training.

All information and data must be handled sensitively and processed in accordance with the Council
Data Protection Policy. In particular, no employee shall divulge personal information regarding any
employee, person or contractor, having dealings with the Council and information relating to tenders
or other such issues.

All Employees must:

• Understand the main concepts within the UK GDPR requirements, these include the
six principles, ‘Lawful basis for processing’ and ‘Right of an Individual.
• Identify and report any risks to the security of personal data processed by the
Council to their line manager or the Information Asset Owner.
• Assist their customers/service users to understand their rights and the Council responsibility
regarding UK GDPR.
• Identify and report any subject access requests to the Data Protection Officer
(DPO) so that they can be processed in accordance with the UK GDPR
requirements.

Under the Data Protection Legislation, individuals have the right to see their own personal data held
subject to the rights of confidentiality of any third parties involved in that information. If you receive
a request to see personal data, please refer to the Council Data Protection Officer for further
information and contact data.protection@publicagroup.uk.

If you become aware of a data protection breach, this must be reported to the Data Protection
Officer (DPO) via email at data.protection@publicagroup.uk or call 01993 861194.

This should be done at the earliest possible stage as the Council has a duty to report any personal
data breaches to the Information Commissioners Office (ICO) with 72 hours of the breach.

If you are able to rectify the breach, this should be done immediately, however, the breach must still
be reported.

3.5 Outside Employment and Voluntary Work

You must obtain permission from your manager before taking any other paid or unpaid employment
or operate an outside business. Even with permission, you must not:

 Participate in an outside employment activity that could have an adverse effect on your ability
to perform your duties at the Council or conflict with our work.
 Ensure that any additional employment does not conflict with the interests of the Council or
affect your ability and credibility to do your job.
 Use any of our assets, including your ICT equipment, for your other job/business, unless that
job or business is via a contract the Council.
 Use your position to solicit work for you outside employer/business or to obtain favoured
treatment.
 Use our confidential information to benefit your other employer, outside business or
invention.

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Voluntary work must be declared and must not conflict with your role or your ability and capacity to
fulfil your contractual obligations to the Council.

3.6 Declaring conflicts of Interest

To ensure that the Council is aware of any potential conflicts of interests, it conducts an annual
employee declaration process, which requires employees to update their information and disclose
any related party transactions. This is a mandatory requirement, and you are required to complete
this form promptly when requested. You also have the ongoing duty to keep this information up to
date and any changes throughout the year must be notified to the Business Manager for Governance.

3.7 Workplace Relationships and Management of Relatives

Personal and family relationships in the workplace may present an actual or perceived conflict of
interest, particularly when one individual in the relationship is in a position to make or influence
employment decisions regarding the other, such as a relationship between a manager and a direct
line report.

If you are in a personal relationship with a Colleague, Line Manager, Councillor, Contractor, or any
other person working for or with Publica, we ask that this is declared through your annual employee
declaration.

If you think the personal relationship in the workplace may create a conflict of interest or be
perceived to create a conflict of interest, then you should raise this with your line manager initially
with the aim of mitigating any potential conflict in a sensible and proportionate way. The Line
Manager should seek guidance from HR where required. If you do not feel comfortable raising this
with your line manager, this can be reported directly to HR or to an alternative Manager.

Where a former relationship causes an adverse impact or a conflict occurs, this should also be
considered and declared or managed in the same way. If the individuals involved in the relationship
do not believe that there is any conflict of interest, then no further action is required.

If there is any doubt, then advice could be sought from a line manager / HR.

Conflicts can occur in the following cases:

 line-management activity;
 recruitment, promotion or selection processes, including tutoring, mentoring and coaching;
 decisions relating to disciplinary, Unsatisfactory Performance Procedures (UPP) or grievance
procedures;
 decisions relating to pay or remuneration, including overtime;
 decisions regarding access to training or Continuing Professional Development (CPD);
 decisions (eg, deployment), that may lead to perceptions of unfairness by those involved in
the relationship or by others.

If you find yourself in a situation where you may be in a position to influence an outcome relating to
someone you have a personal relationship with, it is your responsibility to highlight this, failure to do
so may result in disciplinary action being taken against you.

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We expect you to act professionally when working with a relative or with someone with whom you
are in a personal relationship with and not allow your relationship to disrupt the workplace or
interfere with your work or judgement. You should seek advice from your manager or HR if there
are any problems.
It is your responsibility to ensure you notify HR should your personal situation change, failure to do
so may result in disciplinary action being taken against you.

3.8 Gifts Hospitality & Sponsorship

The Local Govt Act 1972 states that an employee shall not “under colour of his office or
employment accept any fee or reward other than their proper remuneration (i.e. salary/ pay)”
Therefore, you must not accept any fee or reward for work done undertaken for the Council other
than your pay and allowances as set out in your contract of employment without seeking prior
approval.
If you have been invited by an outside organisation to attend a hospitality event, including but not
limited to, breakfast, lunch, dinner, sporting event, seminar/conference, social or cultural event, and
you wish to accept the offer, your acceptance must be authorised in advance by a manager.
You must not accept hospitality from any organisation that is likely to result in a conflict of interest in
respect of decisions made by the Councils, and other officers. This also applies where the invitation
is considered to be personal but arises from a link with an organisation/contractor as a consequence
of your role within the Council.
Any employee that is authorised to accept hospitality must remember that they are representing the
Council and that all terms and conditions of service still apply.
It is an offence under the Bribery Act 2010 to accept gifts loans, fees, or rewards as an inducement
to act in a certain way in your official capacity.
You must not accept payment from a third party that is known to be or suspected to be, offered
with the expectation that it will obtain a business advantage or where such a business advantage will
be provided in return by the Council.
You must be particularly sensitive to the timings of offers of gifts or hospitality in relation to
decisions that the Council may have taken, or be about to take, which affect those providing the gift
or hospitality.
A one-off gift of a low nominal value (less than £25) will generally be authorised for acceptance
provided it does not compromise your position, or that of the Council. With regards to high value
or regular gifts/offers of hospitality, it must be demonstrated there is a genuine business reason
and/or need to accept any such offer.
If an external organisation wished, or is sought to sponsor a Council activity, the rules concerning
acceptance of gifts or hospitality apply. Particular care must be taken when dealing with contractors
or potential contractors. Where the Council wishes to sponsor an event, or service, employees or
members of an employee’s family must not benefit until full disclosure of interest has been made and
approved in advance by the CEO / Head of Paid Services.
All sponsorship and offers of hospitality, regardless of whether it is accepted or not must be
recorded using the Gifts, Hospitality and Sponsorship Approval Form. Failure to do this may lead to
disciplinary action up to and including dismissal.

Please refer to the Employee Gifts, Hospitality and Sponsorship Procedure and Process.

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3.9 Bribery, Corruption and Fraud

The Council will not tolerate any instances of bribery, corruption, fraud, or theft. This includes
abuse of position and will result in disciplinary action and may also result in criminal proceedings
against you. Employees must ensure they are familiar with the Counter Fraud and Anti-Corruption
Policy.

Contract and procurement fraud, both internal and external, is not acceptable under any
circumstance. You must act with integrity and honesty in all your business activities, and you must
be particularly vigilant if your role involves any of the following:

 Raising requisitions for goods and services;

 Authorising the procurement of goods and services;
 Writing of specifications or reviewing tenders for the supply of goods and services;
 Contract management or monitoring or;
 Amending or creating suppliers or customers in Business World.

3.10 Working with Contractors

If you have a relationship or a business, of private nature with external contractors, or potential
contractors, this must be disclosed to the appropriate manager and recorded on your annual
declaration form. Refer to section 5 of this document.
Orders and contracts must be awarded on merit and by fair competition against other tenders. No
special favours should be shown to business operated or controlled by, for example, friends,
partners, or relatives in the tendering process. You must comply with the Contract Procedure Rules
of the Council at all times.

3.11 Public Comment on Council Policy and Administration

It is important that enquiries from the news media are properly handled in order to maintain
effective public relations and to protect the Council’s reputation. As such, Employees must not deal
directly with the press or the media unless required to do so in the course of their work or they
have been expressly authorised by the Communications and Marketing Team. Approaches from all
press, radio, TV stations or specialist press for information or comment on issues affecting the work
of the Council must be referred to the Communications and Marketing Team, who will discuss the
nature of the story and then contact the appropriate officer or member asking them to respond. Any
article, publication, or interview given on aspects of Council policy or activity must be properly
authorised.
Any invitations to undertake lectures or presentations at conferences or seminars in the public
domain, or any literature being produced for publication concerning any Council matter must be
authorised by the Communications and Marketing Team.
It is important that no financial information is released by any employee. Please refer any such
requests to the S151.

Employees should not publicly express personal opinions on Council Policy, activity or
administrations in a way that would bring the Council into disrepute.

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3.12 Use of Social Media Accounts

You should be aware that social networking websites are public forums, and you should not assume
that your entries will remain private. When communicating via social media you must not conduct
yourself in a way that brings the Council or any employee or councillor into disrepute or disclose
information that is confidential to the Council. If you do, even if your social media is a personal site,
disciplinary action can still be taken, up to and including dismissal.

It is advised that unless required, you remove any connection to the Council from your personal
social media sites and not state who you work for. It is understood that some sites, such as LinkedIn
require employment details as the site is about increasing business connections, however, sites such
as Facebook, Instagram and other similar sites should ideally not include references to your
employment. This is both for employee protection and to potential disciplinary action.
You must not use your personal social media sites when conducting work for the Councils.
When using any social media platform, you must follow the guidelines set out in Annex B.

3.13 Personal Investments

Council employees must consider any personal investments they have which give rise to a conflict of
interest if the Company in which the investment is held is transacting business with the Council. If a
real or apparent conflict arises you must disclose the conflict to your manager. Your manager will
help determine whether a conflict exists and, if appropriate, the best approach to eliminate conflict.
Your manager may advise you to update your Employee Declaration Form.

3.14 Using the Council Money (Public Purse)

As public servants, you must ensure that public funds are spent in a responsible and lawful manner.
You must strive to ensure value for money is realised and avoid legal challenge to the Council.

If you have responsibility for budgets and/or purchasing, you must ensure that you understand and
comply with the relevant Standing Orders and Financial regulations.

As an employee of the Council you must adhere to the Procurement Policy, procedures and
controls.

3.15 Side Deals or Side Letters

All the terms and conditions of agreements entered into by the Council, must be formally
documented. Contract terms and conditions define the key attributes of the Council’s rights,
obligations, and liabilities and can also dictate the accounting treatment given to a transaction.
Making business commitments outside the formal contracting process, through side deals, side
letters, or otherwise is unacceptable. You must not make any oral or written commitments that
create new agreements or modify existing agreements without obtaining approval through the formal
contracting process.

3.16 Political Activities

You must ensure that your right to engage in political or professional activities does not result in an
actual or perceived conflict of interest with your work and you should ensure that you are able, and

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be seen to be able, to remain unbiased in the performance of those duties. You must not allow your
own personal or political opinions to interfere with your work and you must not use the Council
assets (including work time, premises, equipment, or funds) to personally support candidates to
campaigns.
Some posts are politically restricted. If you are employed in one of these posts, you must not
undertake political activities either in or outside the workplace. Politically restricted employees will
automatically be disqualified from standing for, or holding, political office and these restrictions are
incorporated as terms in an employee’s contract of employment under the legislation.
Employees who are politically restricted are:

 Barred from standing for office as any of the following:

o Local Councillors (including Town/Parish Councillors).
o Members of Parliament.
o Members of the Welsh Assembly.
o Members of the Scottish Parliament.

 Restricted from canvassing on behalf of a political party or a person who is or seeks to be a

candidate.
 Not permitted to speak to the public at large or publish any written or artistic work that
could give the impression that they are advocating support for a political party.
 Particular care should be taken with social media posts.

3.17 Working with Members

You must treat all political groups and individual Councillors equally, fairly and remain politically
neutral at all times. You must provide professional, impartial, and effective support, to enable
Councillors to fulfil their role, in and on behalf of, the Council.
You must not seek to influence or lobby a Councillor with regard to personal issues.
It is important that there should be good working relationships between senior officers and
Leaders/Members of the Cabinet and Chairs of Committees. However, such relationships must not
be allowed to become so close as to cast doubt either on an officer’s ability to deal impartially with
other Councillors, or the Councillor’s ability to deal impartially with other employees.

3.18 Trade Union Representatives

If you are a workplace representative of a trade union or a professional association, you must ensure
that when you make a public comment, it is clear that any such comment is made on behalf of the
union or association you represent and not the Council. Provisions relating to time to undertake
official union roles are outlined in the facilities agreement.

3.19 Closed Organisation

If you are a member of any organisation that is not open to the public and in respect of which
secrecy about rules or membership or conduct exists you must disclose this on the Annual Employee
Declaration.

3.20 Community Activities and Public Positions

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The Council complies with all relevant laws and regulations and operates in ways that benefits the
communities in which it serves. We encourage you to uphold this commitment to the community
and your activities. If you hold an elected or appointed public office while employed at the Council
you must disclose it as part of the Employee Declaration process. It is important that you do not get
involved in any decisions that might create or appear to create a conflict of interest.

3.21 Criminal Charges, Convictions and Misconduct

You must conduct yourself in a professional manner at all times at work. Serious misconduct and/or
criminal offences committed during or outside of working hours which bring you, or the Council into
disrepute may be the subject of disciplinary action which could lead to dismissal. The Council
requires all applicants for jobs to disclose all contraventions of, or failures to comply with, any
provisions of law, whether committed in the UK or elsewhere, unless the Rehabilitations of
Offenders Act applies, and the rehabilitation period has expired. In some circumstances, Disclosure
and Barring Service (DBS) checks are conducted on successful applicants for certain positions in the
Council.
Once you are an employee, you must notify the Council in writing if you are charged with any
criminal offence, or if you are convicted of any offence. If you are charged with an offence, the
notice must be given immediately after you are charged (i.e. the next working day). If you are
convicted of an offence, the notification must be given immediately after you are convicted (i.e. the
next working day). It should be noted that the term “conviction” includes a finding of guilt regardless
of whether a conviction is recorded. Failure to notify the Council in either case will constitute
grounds for disciplinary action.

3.22 Respecting the Council

We expect you to spend all of your contracted hours working for the Council. Computers and
software (e.g. email, internet) may only be used in line with our guidelines. The use of Council
property or facilities (stationery, photocopiers, etc.) for personal reasons is not acceptable. If you
want to publish any material which you have written in connection with your role you must first gain
the consent of your manager. If, in the course of your work, you create copyright work (for
example a procedure manual or a software programme) a patented invention, or design capable of
registration, this will become the property of the Council and you may be required to cooperate in
the Registration Formalities.

3.23 Security

You must visibly display your Identification Badge at all times while you are on any Council premises.
All employees are required to challenge anyone in an employee and/or secure area of the Council
premises without either an Employee ID or Visitor’s Badge.

You must not allow any individual not displaying an ID Badge to follow (“tailgate”) you into any
secure area of the Council premises.

If you come to work without your badge, you must report to the Council reception point to collect
and use a temporary replacement. If you lose your ID Badge, you must report it immediately to your
manager. You will be required to pay for a replacement.

If you have a visitor coming to see you at the Council premises, you must ensure that they sign in/out
at reception and are issued with a visitor badge. You must ensure that they are escorted around the
building whilst onsite.
Part E2: Employee Code of Conduct 1 April 2024
3.24 Use of Information Technology

Employees must use any ICT equipment or facilities provided by the Council for use in the course of
their employment in a proper and responsible manner. The Council is entitled to expect at least the
same standard of care of its property as employees give to their own property.

Employees must adhere to the Council ICT Acceptable Use Policy and associated guides at all times.
This Policy outlines the obligations on the part of Council employees and other contractors
regarding the acceptable use of Council owned ICT devices and the steps the Council may take to
ensure security compliance.

The content of the Council IT resources and communications systems are the property of the
Council. Therefore, staff should have no expectation of privacy in any message, files, data, document,
telephone conversation, social media post conversation or message, or any other kind of information
or communications transmitted to, received, or printed from, stored, or recorded on the Council IT
and communications systems.

The Council reserves the right to monitor, intercept and review, without further notice, an
employees use of the IT resources and communications systems, including but not limited to emails,
social media postings and activities, to ensure that its rules are being complied with and for legitimate
business purposes.

Failure to follow the ICT Acceptable Use Policy may lead to disciplinary action under the Council
Disciplinary Policy.

3.25 Internal Audit, Counter Fraud and Risk and Opportunity Management

The Council is subject to internal audit services and counter fraud inspections and investigations. All
employees have a responsibility to contribute to this work, and where actions have been agreed, and
you are responsible for progressing that action, it is your responsibility to ensure it is addressed
within the agreed timescale.

The Council has a risk and opportunity management framework. All employees have a role to play in
the identification and assessment of risk and the implementation of controls, where applicable.

3.26 Reporting Breaches of the Code and Whistleblowing

If you are concerned about any practice you see in the Council which you think conflicts with the
Code of Conduct, you should obtain advice from your Manager, Monitoring Officer or Trade Union
representative, or any other appropriate person as identified in the Council policies referred to in
the Code of Conduct.

The Public Interests Disclosure Act 1998 and Council Whistleblowing Policy can provide safeguards
for employees and public officials who disclose unlawful and improper conduct including breaches of
this Code.
Public Interests Disclosure / Whistleblowing concerns should be raised with a member of the HR
Team, Internal Audit or the Counter Fraud and Enforcement Unit. Please refer to the
Whistleblowing Policy for other ways to report concerns.
Any suspicion of money laundering must be reported in the first instance to the S151. Please refer to
the Council Proceeds of Crime and Money Laundering Policy for specific information.

Part E2: Employee Code of Conduct 1 April 2024

3.27 The role of a Manager at the Council

As a manager, you have a responsibility to set a good example for employees through your own
behaviour and attitudes, especially in relation to upholding the ethical principles, obligations,
behaviours, and the standards as set in this Code of Conduct.

You should ensure that you understand your responsibilities under relevant financial, legal
procurement, technological, human resources, and other relevant policies and procedures,
maintaining the principles of accountability, continuous improvement, fairness, flexibility, and equity in
the workplace.

You should ensure that employees understand performance standards expected from them and
objectively assess their performance against these standards. This should be achieved through the
Council appraisal process and regular one-to-one’s. As a Manager, you must ensure that your
employee received an annual appraisal, which is reviewed as part of your one-to-one meetings. If an
employee is not meeting the expected performance standards, you should refer to the Performance
Improvement Procedure.

You must ensure that relevant legislation, delegations, and Council policies and procedures are
accessible to all employees in your business area, and that both yourself, and they understand their
obligations under this Code of Conduct.

You should ensure that all employees who report to you are familiar with the requirements and
objectives of their job, and have access to the information, training, supervision, feedback, and work
conditions needed to achieve them.

You are required to act promptly, thoroughly, and fairly when responding to, or investigating
grievances and reports of breaches of the Code of Conduct. To avoid any accusation of bias, you
must not be involved in the appointment of any applicant if you are a relative or friend to them.

Similarly, you must not be involved in decisions relating to discipline, promotion or pay adjustments
for any employee who is a relative, partner or friend. If you are in any doubt, you should discuss the
matter with your manager.

Part E2: Employee Code of Conduct 1 April 2024

 Nolan Principles

Selflessness
Holders of public office should act solely in terms of the public interest.

Integrity
Holders of public office must avoid placing themselves under any obligation to people or
organisations that might try inappropriately to influence them in their work. They should not act or
take decisions in order to gain financial or other material benefits for themselves, their family or their
friends. They must declare and resolve any interests and relationships.

Objectivity
Holders of public office must act and take decisions impartially, fairly and on merit, using the best
evidence and without discrimination or bias.

Accountability
Holders of public office are accountable to the public for their decisions and actions and must submit
themselves to the scrutiny necessary to ensure this.

Openness
Holders of public office should act and take decisions in an open and transparent manner.
Information should not be withheld from the public unless there are clear and lawful reasons for
doing so.

Honesty
Holders of public office should be truthful.

Leadership
Holders of public office should exhibit these principles in their own behaviour. They should actively
promote and robustly support the principles and be willing to challenge poor behaviour wherever it
occurs.

Part E2: Employee Code of Conduct 1 April 2024

 Social Media Guidelines
There is often a fine line between the use of social media as a work tool and your personal use as an
individual outside of your work role. Sometimes your opinions may conflict so you must take care to
separate the two when that happens.
The Council recognises that many employees make use of social media in a personal capacity. While
you may not be acting on our behalf, you must be aware your actions can damage the Council if
you’re recognised as being one of our employees.
If you use social networks or blogs for personal use and have indicated that you work at the Council,
you should consider using a disclaimer that states that opinions on this site are your own. An
example: ‘The views expressed are my own and don’t reflect the views of my employer.’
When posting on social media you should:
1. Always be mindful of the impact your contribution might make to our reputation.
2. Remember you are personally responsible for all content you publish.
3. Not upload, post or forward any content that is abusive towards your colleagues, members
of the public or the Council as an organisation. It could result in disciplinary action if you do.
This includes any content that is abusive, obscene, discretionary, harassing, derogatory or
defamatory.
4. Never disclose commercially sensitive, anti-competitive, private, or confidential information.
Also, do not breach copyright, for example by using someone else’s images or written
content without permission.
5. Be aware that what you publish will be around for a long time so consider the content
carefully and also be sensible about disclosing sensitive details.
6. Remember that social media networks, blogs and other types of online content sometimes
generate press and media attention or legal questions. You must refer these enquires to the
Communications team.
7. Be conscious that our reputation is made by your behaviour. Everything you publish reflects
how we are perceived. Please ensure you’re aware of our values and reflect these.
8. Ensure that if you identify that inaccuracies about the Council have been published in a public
forum, you may politely and sensitively point out the factual inaccuracies but should refrain
from entering into a debate. You should also advise the Communications team that you have
identified information that is inaccurate or could damage our reputation.
9. Ensure compliance with data protection legislation – for example moving the discussion to
private message (Facebook) or direct message (Twitter) when personal details need to be
discussed. Alternatively, ask them to contact us another way e.g. telephone.
10. Block, hide or ban abusive users.
11. Pay particular attention during the pre-election periods, when special care needs to be taken
to ensure that any content you post, share or like is not seen as promoting any political
group or individual candidate.
12. Consider the privacy settings on your social media accounts if you are in a public facing role
where your name may be published as part of your job. Consider limiting access to your
profiles so that people cannot look up your personal accounts and information.

Part E2: Employee Code of Conduct 1 April 2024

You must not use your personal social media sites when conducting work for the Council. Where
the internet or social media is required for enforcement purposes, please refer to the Use of the
Internet and social media for Investigations and Enforcement Policy.

Part E2: Employee Code of Conduct 1 April 2024