Code of Conduct


Code of Conduct

Model HR Policies and Procedures for 
Schools and Academies


Contents Page


Click on the relevant heading below which are hyperlinked for ease of use.









Compliance with the Code of Conduct



Professional behaviour and conduct          




Treating other people with dignity and respect




Appropriate relationships with children




Associating with people outside work




Misuse of position




Dealing with Media enquiries




Criminal actions



Declaration & conflict of interest








Conflict of interest




Intellectual property







 Information protected by the General Data Protection Regulation (GDPR) and Data Protection Act 2018



Appointment, Pay & conditions and other Employment Matters




Investigations by Professional bodies




Financial conduct




Tendering for business 




Holding multiple positions 




Dress and appearance 



Probity of records and other documents



Financial inducements




Financial Regulations for schools




Business Contacts




Declaration of gifts




Gifts or hospitality to an employee




Gifts to children 



Use of School contacts



Health and safety



Use of alcohol and drugs



Use of school premises, equipment & communication systems



Social networking websites, Personal Websites and Blogs



Obligations under the General Data Protection Regulation (GDPR) and Data Protection Act 2018




Managing data




Disclosing data



Declaration form 


Appendix 1

Register of Business Interests Form            


Appendix 2

Register of Gifts and Hospitality




1.     Scope

This policy applies to all staff directly employed by schools and academies. 

For Academies, all reference to school should be taken to mean Academy, all reference to the Headteacher should, where appropriate, be taken to mean Executive Headteacher/Principal/Head of School, and all reference to the Governing Body should, where appropriate, be taken to mean the Academy Trust

Under this policy, the Headteacher will be required to make any declarations to the Chair of Governors.

2.     Introduction

The school is committed to the highest standards of honesty and accountability; and this Code of Conduct provides the values and framework within which all staff, volunteers and contractors are required to adhere to in their work environment. This Code cannot cover every eventuality and is not an exclusive or exhaustive list of acceptable conduct at work.  

All employees have personal and legal responsibilities, including; treating others with dignity and respect; acting honestly, using public funds and school equipment appropriately, adhering to health and safety guidelines and practising equal opportunities at all times.  Various Professional and technical bodies may have their own code of conducts e.g. The National College for Teaching and Leadership (click here: for the Teachers’ Standards), these should work in tandem with this document, and where any anomalies arise this should be raised with the Headteacher at the earliest opportunity. Employees should also seek guidance if they are unsure about the contents of this document or if there are any questions as to whether particular conduct or behaviour is acceptable.

3.     Compliance with the Code of Conduct

This Code of Conduct forms part of an Employees contract of employment. As such this code must be read, understood and adhered to. Any failure to do so will lead to action in line with the school’s Disciplinary Policy and Procedures and, if warranted, legal action. Ignorance of these guidelines will not be seen as a valid excuse.

Appropriate action will be taken with volunteers and contractors as required, where it is considered that the actions of a volunteer or contractor are in breach of this code, the school will consider not using their services.


4.     Professional behaviour and conduct

      4.1.    Treating other people with dignity and respect

All employees are expected to treat other colleagues, pupils, and external contacts such as parents, with dignity and respect, in compliance with the school’s equality policies. Unacceptable behaviour such as discrimination, bullying, harassment or intimidation will not be tolerated. This includes physical and verbal abuse and use of inappropriate language or unprofessional behaviour with colleagues, pupils and parents etc.


    4.2.     Appropriate relationships with children

All employees are expected to act in an open and transparent way that would not lead any reasonable person to suspect their actions or intent. Employees in schools are in a position of trust and have a duty to protect young people from discrimination and harm and to maintain appropriate professional boundaries. It is equally important for staff to avoid behaviour that might be misinterpreted by others in order to protect both young people and themselves. For further guidance employees should refer to Guidance for Safer Working Practice for Adults who work with Children and Young People in Education Settings which sets out appropriate and safe behaviours for all adults working with children in paid or unpaid capacities.

Conduct that may be considered in this way may include personal arrangements to see pupils, service users, their carers or families and exchanging personal contact details such as email, texts and communicate using social media.  

Employees must refrain from conduct of this nature unless there is a sound business reason to do so, and the action is taken with the express approval of the Headteacher, and the decision is officially recorded.  (See the school’s Child Protection/Safeguarding Policy).

     4.3.    Associating with people outside work

Employees who engage in any activity or associate with individuals or people outside work, whose current or past conduct could raise doubts or concerns about an employee’s own integrity or ability to be in a ‘position of trust’ with regard to children or vulnerable adults, could have a direct consequence on their employment via the disciplinary procedures. 

Staff who are required to complete a Childcare Disqualification declaration under the Childcare (Disqualification) Regulations 2009 must make an accurate disclosure and notify the school if their circumstances change. The Regulations prohibit anyone who is disqualified under the Regulations, or who lives in the same household as a disqualified person, from working in a relevant setting, including in schools. For further information and guidance see Childcare Disqualification requirements check.

     4.4.     Misuse of position

Employees must not misuse or misrepresent their position, qualifications or experience or bring the reputation of the school into disrepute. Such behaviour may lead to disciplinary action and where relevant, referral to the relevant professional body e.g. National College for Teaching and Leadership. Similarly employees should not put themselves in a position where their job and personal interests conflict. 

     4.5.    Dealing with media enquiries

Employees must not deal directly with the press or the media in relation to anything related to school business unless required to do so as part of their duty, or authorised by the Headteacher.  

Employees who speak as a private individual directly to the press or at a public meeting or other situation where remarks may be reported to the press must ensure that reasonable steps are taken to ensure nothing is said that might lead the public to think they are acting in the capacity as an employee of the school.

    4.6.    Criminal actions

Employees must inform their manager if they are arrested/convicted/cautioned of a crime and, if arrested, must notify the manager of the development and outcome of the case as soon as it happens. Employees do not need to disclose fixed penalty notices for minor driving offences, such as speeding tickets, defective light etc, unless driving is a requirement of an employee's role or the conviction results in disqualification. The Headteacher will discuss this with the employee in the context of their role and responsibilities in order to help safeguard children and other employees at the school.

Disclosing a conviction does not necessarily mean disciplinary action against an employee. 

The extent to which a criminal offence may affect employment depends on whether the conduct: 

  • Makes the employee unsuitable for their type of work; and/or 
  • May reflect adversely on the school’s reputation or ability to perform its function. 

Employees should always notify their manager if there is any doubt as to whether or not they need to share information about an arrest or conviction.

Failure to disclose such information may lead to disciplinary action.  

5.     Declaration & conflict of interest  

An employee is required to declare this where the situation e.g.  group or organisation would be considered to be in conflict with the ethos of the school. Membership of a trade union or staff representative group would not need to be declared. Employees should also consider carefully whether they need to declare to the school their relationship with any individual(s) where this might cause a conflict with school activities, for example, a relationship with a governor, another staff member or a contractor who provides services to the school. Failure to make a relevant declaration of interest is a serious breach of trust and therefore, if employees are in doubt about a declaration they are advised to take advice from the school or union. All declarations, should be submitted in writing to the Headteacher on a school Register of Business Interests, (Appendix 1). 

      5.1.     Transparency

Employees must declare in writing to the Headteacher any relatives or partners, or friends who are engaged in a business, which either currently provides services to the school, or schools with which a school collaborates or is federated to, or may do so in the future. This is in order to minimise the risk of suspicion that some influence may be exerted over a particular customer as to the choice of provider, or that the provider gained advantage in terms of information received. 

    5.2.    Conflicts of interest 

Employees who have a connection in a private, social or domestic capacity with someone who also sits on a school’s Governing Body that may potentially create, or be thought to create, a conflict of interest will need to declare this to the Headteacher, for them to consider (see appendix 2). 

Employees must not work privately for personal gain unless written consent from the Headteacher has been obtained.


   5.3.   Intellectual property

The school is entitled to ownership of intellectual property e.g. copyright of material created by the employee in the course of duties carried out by the employee of the school.

Employees must not use any information obtained in the course of employment for personal gain nor pass it on to others who might use it in such a way or for any purpose for which it was not originally intended. 

6.     Confidentiality 

     6.1.    Information protected by the General Data Protection             

    Regulation (GDPR) and Data Protection Act 2018

No confidential information, politically or commercially sensitive information, or personal information protected by the General Data Protection Regulation (GDPR) and Data Protection Act

2018 should be released to anyone, including governors, without authorisation from the Headteacher. If there is any doubt about disclosing information then guidance from the Headteacher must be sought.

Employees at the school and the governing body come into contact with a significant volume of data and information in relation to pupils, staff, school activities and many other matters. There is an obligation to read and to observe the requirements of the General Data Protection Regulation (GDPR) and Data Protection Act 2018.

7.     Appointment, pay & conditions and other employment matters

Employees responsible for the appointment, pay and conditions or any other employment matters must ensure that decisions are fair, open and based on merit and not on anything other than an individual’s ability to do the job and in accordance with the school’s related policies and procedures.  

If an employee is put in a position of being the line manager to a relative, close friend or partner this must also be immediately disclosed. Employees must not be involved in the recruitment and selection for anyone with whom they are in a close personal relationship with outside of work. See Recruitment and Selection Policy.


    7.1.     Investigations by Professional bodies

Employees must inform their manager if they are being investigated by any professional body and any sanction imposed.  

If employees are in doubt about any of the above, advice from the Headteacher must be sought, in the first instance. 

     7.2.    Financial conduct

Employees must inform the Headteacher if they are declared bankrupt or are involved as a Director of a company which is wound up or put into voluntary liquidation if it may impact upon their role and duties. Bankruptcy may impact on the duties of employees who have a financial responsibility. 

Such information will be treated in the strictest confidence. The purpose of this is to ensure that a proper framework of support is in place.

     7.3.   Tendering for business 

Employees who wish to tender for a contract from the school must declare such an intention to the Headteacher as soon as intent has been formed; and at the earliest possible opportunity.

     7.4.   Holding multiple positions

All staff employed by the school in any capacity must be mindful of the local conditions of service and requirements placed upon them in holding multiple positions. 

Staff must ensure that any additional posts held do not interfere with employment at the school or have any conflict of interest with the school or bring it into disrepute.

Staff must be mindful of their responsibility under the Working Time Regulations 1998; Staff cannot lawfully be required to work more than an average of 48 hours per week. Where staff work in excess of an average of 48 hours per week they will be required to write to the school, confirming that they agree to opt out of the working time regulations. 

Employees who are permitted to engage in any other business or take up any additional employment must not undertake any work in connection with their additional employment during the time in which they are scheduled to be in the school. It is the responsibility of each individual employee to declare any additional personal income to Her Majesty’s Revenue and Customs (HMRC). 

Employees who have any doubt whatsoever should make a declaration, so that the Headteacher can make a judgement as to whether a conflict exists. 

  7.5.   Dress and appearance

The school recognises the diversity of cultures and religions of its employees and will take a sensitive approach when this affects dress and uniform requirements. However, priority will be given to health and safety, security and other similar considerations.

All employees must present a positive image of the School and are therefore required to present a professional appearance and dress appropriately for the role that they perform. Examples of inappropriate clothing and appearance can include:

  • scruffy/torn trousers;
  • short miniskirts;
  • low cut t-shirts, blouses and transparent clothing;
  • sweatshirts or t-shirts with slogans or symbols that could cause offence;
  • Excessive or unconventional jewellery.
  • Extreme hairstyles
  • Visible tattoos are discouraged and must be discreet

8.    Probity of records and other documents

Where an employee falsifies records or other documents, including those held electronically, this will be regarded as a serious disciplinary matter and potentially a criminal offence. 

9.       Financial inducements

      9.1.   Financial Regulations for schools

All school employees must comply with the school's Financial Regulations. Employees should familiarise themselves with the regulations; some of the principal employee requirements are summarised below.

     9.2.   Business Contacts

Business contact refers to any person, body or organisation with which the school is involved on a financial or charitable basis (including contractors; developers; consultants; regional or national charities). This also includes business contacts who are potential suppliers (e.g. they are tendering for future business).

   9.3.   Declaration of gifts

Staff should avoid accepting gifts as it can be construed as a bribe by others or may lead the giver to expect preferential treatment.

Any gifts that are received should be declared in writing to the Headteacher on the Register of Gifts and Hospitality (Appendix 2) with the exception of those items specifically identified in section 7.4, below. The Headteacher is required to make any declarations to the Governing body.

   9.4.   Gifts or hospitality to an employee

Where a business contact offers a personal gift, personal payment or other incentive such as secondary employment to an employee, these should not be accepted and should be returned with a suitable official letter. Such offers should be declared to the Headteacher and recorded in the Register of Gifts and Hospitality.

If it is not possible to return gifts then the employee who deals with that supplier should declare the gift to the Headteacher who will keep a record of it and decide how it is to be used. Such gifts remain the property of the school and should be included in the Register of Gifts and Hospitality.

The only exceptions to these are:

  • Low cost, functional items suitable for business use rather than personal use and displaying the supplier’s logo e.g. diaries, calendars and pens. These items may be accepted and do not have to be included in the Register of Gifts and Hospitality.
  • Gifts offered by parents or students to school staff to express their thanks, such as boxes of chocolates should only be of token value. Such gifts do not have to be declared in writing to the Governing Body or be included in the Register of Gifts and Hospitality. For the avoidance of doubt employees must always refuse gifts of money. All other gifts that are received should be declared in writing to the Headteacher on the Register of Gifts and Hospitality (Appendix 2)

Where hospitality in the form of meals and drinks is offered by a business contact, this is only acceptable where it forms part of a normal business meeting (for example, refreshments at training events or meals at evening meetings). Offers of hospitality to specific events, such as a dinner or sporting event, should only be accepted after authorisation from the Headteacher. These would normally only be approved where there is a clear and demonstrable benefit to the school and the hospitality would not expose the school to criticism that the business contact was exerting undue influence. These should be recorded in the Register of Gifts and Hospitality.

     9.5.   Gifts to children

Under no circumstance must staff offer or give gifts to children. This could be misinterpreted as a gesture either to bribe, or single out the young person. It might be perceived that a 'favour' of some kind is expected in return. Any reward given to a young person should be in accordance with agreed practice within the school.

10.    Use of school contacts

Apart from participating in concessionary schemes arranged by Trade Unions or other such groups for their members, employees shall not use school business contacts for acquiring materials or services at trade / discount prices for non-school activities unless authorised by the Headteacher .

11.    Health and safety

Employees must adhere to the school’s Health and Safety policy, procedure and guidance and must ensure that they take every action to keep themselves and everyone in the school environment safe and well. This includes taking immediate safety action in a potentially harmful situation (either at school or off-site) by complying with statutory and school guidelines and collaborating with colleagues, agencies and the local authority where required.

12.     Use of alcohol and drugs

The taking of illegal drugs and ‘legal highs’ is unacceptable and will not be tolerated. All employees are expected to attend work without being under the influence of alcohol or drugs and without their performance being adversely impacted by the consumption of alcohol or drugs. If alcohol or drug usage impacts on an employee’s working life, the school has the right to discuss the matter with the employee and take appropriate action, having considered factors such as the school’s reputation and public confidence.  Further details are available on the Schools’ Alcohol & Drug Abuse policy.

13.     Use of school premises, equipment & communication systems

School equipment and systems (telephone, email, computers etc.) are available only for school related activities and should not be used for the fulfilment of another job or for personal use, unless authorised by the Headteacher. 

This includes photocopy facilities, stationery and premises. It also applies to access provided for remote use (e.g. hand held portable devices etc.) and to staff working outside of school premises and using their own IT equipment. Illegal, inappropriate or unacceptable use of school equipment or communication systems may result in disciplinary action and in serious cases could lead to an employee's dismissal. The following list sets out some examples but is not an exhaustive list: 

  • Creating, sending or forwarding any message that would reasonably be considered inappropriate or unacceptable.
  • Accessing, publication or circulation of illegal, offensive, unacceptable or inappropriate material
  • Any illegal activities.
  • Posting confidential information about the school and/or other employees, children or parents etc.
  • Gambling or gaming.
  • Unauthorised use of school facilities
  • Use of Social Media on school owned devices unless it is in accordance with the schools policies and procedures.

Employees receiving inappropriate communication or material, or who are unsure about whether something they propose to do might breach this policy, the Schools ICT usage policy, Social media policy or other related policy should refer to these policies for guidance or seek advice from the Headteacher.

The school has the right to monitor e-mails, telephone calls, internet activity or document production, principally in order to avoid offensive or nuisance material and to protect systems from viruses, but also to ensure proper and effective use of systems and equipment.

Communication systems may be accessed when the school suspects that the employee has been misusing systems or facilities, or for the investigation of suspected fraud or other irregularity. Passwords should not be shared and access to computer systems must be kept confidential. Breach of this confidentiality may be subject to disciplinary action. Where appropriate the school will consider a system of proxy access. The school will deal with breaches in line with the appropriate policy. 

 Any school equipment that is used outside school premises, for example laptops, should be returned to the school when the employee leaves employment or upon the Headteacher’s request. 

14.     Social networking websites, personal websites and blogs

Only official school sites must be used for communicating with pupils or to enable pupils to communicate with one another. There must be a strong pedagogical or business reason for creating official school sites to communicate with pupils or others, and written consent from the Headteacher must be obtained. Sites created must not breach the terms and conditions of social media service providers, particularly with regard to minimum age requirements Staff must not create sites for trivial reasons which could expose the school to unwelcome publicity or cause reputational damage

The Social Media policy and ICT Usage policy provides further advice and guidance. 

15.     Obligations under the General Data Protection Regulation (GDPR) and Data Protection Act 2018

    15.1.     Managing data

Where staff are required to collect, maintain and dispose of sensitive or personal data it is done so in in line with the General Data Protection Regulation (GDPR) and Data Protection Act 2018.

     15.2.     Disclosing data

Staff should not disclose sensitive information about the school, its employees or pupils to other parties, for example, parents or colleagues. There are particular exceptions to this; for example disclosure of suspected or alleged abuse of a pupil to Child Protection officers; discussion with a person accompanying or representing an employee in a formal meeting or disclosure under the Whistleblowing Procedure. All communication with the media must be directed through the Headteacher or their nominee, who will have sought advice from the appropriate source e.g., the Local Authority’s communication department. There are circumstances in which staff are obliged to release pupil data, for example, parents seeking information about their child

Staff should be aware that, from time to time, information about employees’ salaries is matched with other public sector information in order to prevent fraudulent claims.

16.     Declaration form

I declare that I have read and understood the Code of Conduct and the associated “Required Reading”.


Name_______________________________________ Date______________________


Signature_______________________Job Title:________________________________



Appendix 1


Staff declaration form

I wish to declare the following information in accordance with the Headteacher’s requirements that a Register of Business Interests should be maintained.





You should provide full details of your declaration below:

Name of Business

Nature of Business

Nature of Interest

Date of Appointment or Acquisition

Date of Cessation of Interest

Date of Entry




Appendix 2


Staff declaration form

I wish to declare the following information in accordance with the Headteacher’s requirements that a Register of Gifts and Hospitality should be maintained.





You should provide full details of your declaration below.


Declaration of gifts and hospitality



Date gift received

From whom

Details of the Gift or hospitality