CODE OF CONDUCT FOR SEDGEMOOR TENANTS ASSURANCE COMMITTEE

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Contents

Section		Page
	Introduction	3
	Main Principles of Code of Conduct	3
A	General Responsibilities	5
B	Conflicts of Interests	7
C	Bribery, gifts and hospitality	8
D	Funds and Resources	8
E	Confidentiality	9
F	Respect for Others	10
G	Relationship between Members, staff and involved tenants	11
H	Relationship with tenants and other service users	11
I	Health, safety and security	12
J	Conduct at meetings	13
K	Representing the Company	13
L	Learning and Development	13
M	Reporting Concerns	14
N	Breaches of this Code of Conduct	14
O	Members Removal from STAC	15
P	Acceptance	16

Homes in Sedgemoor – Code of Conduct for Sedgemoor Tenants Assurance Committee
	Introduction
	STAC was created in 2021 with the purpose of supporting the Homes in Sedgemoor Board by providing customer-based assurance that the consumer standards of the ‘Regulatory Framework for Social Housing in England’ are being met; that value for money is being achieved in service delivery to all tenants and leaseholders and is in line with the organisation’s vision and values. STAC has a Terms of Reference which requires members to agree to a Code of Conduct. Homes in Sedgemoor has a formal document called the ’The Code of Conduct for Board and Committee members’ which is based on legal, regulatory and best practice requirements for non-executive directors of social housing providers. The Code of Conduct for STAC is based upon this document and recognises that STAC are appointed as volunteers. The Code of Conduct provides guidance on how to ensure that your actions and behaviour are consistent with the Company’s values and the high standards of conduct required to maintain confidence in the Company and its work. You must familiarise yourself with the contents of the Code of Conduct and act in accordance with its principles and provisions at all times. Failure to comply with the code may be a governance disciplinary matter. If Members have any doubts or questions regarding the application of the Code of Conduct, or in relation to a specific issue, they should seek advice and guidance from the Company Secretary. Reference is made in this document to Members which is designed to cover all Members of the Board and all Members of Committees established by the Board.
	The Main Principles of the Code of Conduct
A	General Responsibilities
	You must fulfil your duties and obligations responsibly, acting at all times in good faith and in the best interest of the Company, its tenants and other service users.
B	Conflicts of interests
	You must take all reasonable steps to ensure that no undeclared conflict arises, or could reasonably be perceived to arise, between your duties and your personal interests, financial or otherwise.
C	Bribery, gifts and hospitality
	You must not offer, seek or accept bribes or inducements to act improperly or corruptly. You must not seek or accept gifts, hospitality or other benefits from individuals or organisations that might reasonably be seen to compromise your judgement or integrity or place you under an obligation to those individuals or organisations. The Gifts and Hospitality Policy provides Members with guidelines as to the level of gifts and hospitality that may be acceptably received or given and to provide a system for such gifts or hospitality to be recorded (including those declined).
D	Funds and resources
	You must not misuse the Company’s funds or resources.
E	Confidentiality
	You must handle information in accordance with the law and the Company’s policies and procedures.
F	Respect for others
	You must treat others with respect at all times
G	Relationship between Members and Staff
	Members must maintain a constructive, professional relationship with staff based on a sound understanding of their respective roles.
H	Relationship with tenants and other service users
	You must maintain high standards of professionalism, fairness and courtesy in all your dealings with tenants and other service users.
I	Health, safety and security
	Your conduct must not endanger the health, safety or security of yourself or others.
J	Conduct at meetings
	Your conduct at meetings must meet a high standard of integrity, commitment and courtesy.
K	Representing the Company
	In representing the Company at external events and in dealings with outside bodies, you must uphold and promote the Company’s values, objectives and policies.
L	Learning and Development
	In partnership with the Company, you must take responsibility for your own learning and development, regularly updating and refreshing your skills and knowledge.
M	Reporting Concerns
	You must report any reasonable and honest suspicions you may have about possible wrongdoing.
N	Breaches of the Code of Conduct
	Breaches of this Code of Conduct will be a disciplinary matter.
O	Members removal from STAC
	Members may be removed from STAC in certain circumstances
P	Acceptance
	Members will be expected to sign this Code of Conduct
A	General Responsibilities
	Main Principle
	You must fulfil your duties and obligations responsibly, acting at all times in good faith and in the best interests of the Company, its tenants and other service users.
	Provisions
	A1 You must comply with the law, your terms of appointment and the Company’s policies and procedures and governance framework relating to your role. A2 You must not conduct yourself in a manner which could reasonably be regarded as bringing the Company into disrepute. This includes membership of, or participation in, activities organised by groups or organisations whose values are inconsistent with the Company’s (for instance, racist organisations) which could create reasonable doubt in your ability to comply with the Company’s values and this Code of Conduct. A3 You must not bring the Company’s name into disrepute or affect its integrity by your actions or words, either within the organisation or outside. This includes the use of, or entries on, social networking sites (such as Facebook, Twitter, YouTube and others). This includes making derogatory comments about the Company, its tenants or other service users, partners or services, either in person or in writing or via any web-based media such as a personal blog or other site. This also applies if you do not name the Company but where its identity can reasonably be inferred, or where you use a pseudonym, but your identity can reasonably be inferred. If you have a genuine concern about possible wrongdoing, you must report it to the appropriate senior person within the organisation (see section M below). A4 You must not act in a way that unjustifiably favours or discriminates against particular individuals, groups or interests. A5 You must respect the appropriate channels for handling tenancy and service provision issues. You must not act outside the Company’s established procedures in any matter concerning any tenant or other service users. A6 You must not misuse your position, for example, by using information acquired in the course of your duties for your private interest or those of others. A7 You must respect the principle of collective decision-making and corporate responsibility. This means that once the Board or Committee has made a decision you must support that decision. A8 You must not engage in any political or campaigning activity that might compromise the position of the Company. A9 If you take up new employment or appointments during your term of office as a member, you must make any necessary declaration of interest. Any such work or position must not interfere with your role as a member.
B	Conflict of interests
	Main Principle
	You must take all reasonable steps to ensure that no undeclared conflict arises, or could reasonably be perceived to arise, between your duties and your personal interests, financial or otherwise.
	Provisions
	B1 You must comply with the Company’s policies and procedures for declaring, recording and handling conflicts of interest. Amongst other things, these require you to declare any personal interest which may, or may not be perceived to, conflict with the duties of your role. B2 You must ensure that your entry in the Company’s register of interests is complete, accurate and up-to-date and complete a declaration of interest form annually. B3 You must comply with the Company’s policies and procedures relating to the application for employment or housing from Members or others to whom they are related or closely connected. B4 You must not be involved in the appointment of staff where you are related, or are closely connected, to an applicant. You must declare any such relationship to the appropriate person. You must not be involved in decisions relating to discipline, promotion, pay or benefits for any member of staff to whom you are related or closely connected. B5 You must not be involved in the appointment of a contractor or supplier where you are related, or closely connected, to an organisation or individual applying or tendering for a contract. You must declare any such relationship to the appropriate person. You must not be involved in establishing the terms of a contract, or its ongoing monitoring and management, where you are related, or closely connected, to the contractor or supplier. B6 Except where specifically permitted by the Chief Executive or Company Secretary, you must normally avoid using the Company’s contractors and suppliers for private purposes. Where this is unavoidable, you must not receive a favourable service as a result of your connection with the Company. Prior approval must be sought before using the supplier or contractor and a written declaration made confirming that no financial or other advantage has been secured as a result of the relationship with the Company. B7 You must not use, or attempt to use, your position to promote your personal interests or those of any connected person, business or other organisation.
C	Bribery, gifts and hospitality
	C1 You must comply with the law and the Company’s policies and procedures in relation to: Bribery and corruption; andThe giving, receipt, approval and recording of gifts and hospitality. C2 You must not canvass or seek gifts or hospitality or other benefits. C3 If you are offered gifts or hospitality, they should either be declined, or prior approval sought for their acceptance. The only exceptions are gifts of token value or modest hospitality given in connection with normal work meetings. The Company’s policies give further guidance.
D	Funds and Resources
	Main Principle
	You must not misuse the Company’s funds or resources
	Provisions
	D1 You must comply with the Company’s policies and procedures regarding the use of its funds and resources. ‘Resources’ includes for example staff, information, telephone, computer and other IT facilities, equipment, stationery and transport. D2 You must ensure that the organisational funds and resources entrusted to you are used efficiently, economically and effectively. D3 You must comply with the Company’s policies and procedures regarding procurement, ensuring value for money and fairness in decision-making. D4 You must take reasonable measures to protect the Company’s funds, resources, property and assets from theft, damage and misuse. D5 You must comply with the Company’s policies and procedures relating to the acceptable or unacceptable use of email, intranet and internet services. Amongst other things, these policies and procedures prohibit access to pornographic or racist material, and the use of unauthorised or unlicensed software. D6 You must claim reimbursement only for expenditure that was properly and reasonably incurred in carrying out the Company’s business. You must ensure that any expenses claim you make is accurate and complies with the Company’s policies and procedures.
E	Confidentiality
	Main Principle
	You must handle information in accordance with the law and the Company’s policies and procedures.
	Provisions
	E1 You must comply with the provisions of the Data Protection Act 2018 and General Data Protection Regulations which govern the protection of personal data. All personal data held about tenants and other service users, employees and others, whether on paper or electronically is subject to the provisions of the Act. The Company’s policies and procedures give further guidance. E2 You must not disclose without authority any confidential business information. This duty continues to apply after you have left the Company or relinquished your position. E3 You must not, without permission, pass or distribute to the press or media or any other external recipient(s) information or materials relating to the Company. E4 In your capacity as a Member, you must not, without prior authority: Appear to represent the views or position of the Company;Write letters to the press or other recipient(s).Write media articles, blog posts or tweets etc., about the Company and its activitiesMake comments or statements to the media – if approached you must pass the enquiry to the appropriate person. E5 You must not prevent another person from gaining access to information to which they are entitled by law.
	Respect for others
	Main Principle
	You must treat others with respect at all times
	Provisions
	F1 You must comply with the law and with the Company’s policies and procedures relating to equality, diversity and inclusion. Equality laws prohibit discrimination on grounds including age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation and impose positive duties to eliminate unlawful discrimination and promote equality. The Company’s policies give further guidance. F2 You must not harass, bully or attempt to intimidate any person. The Company’s policies give further guidance. F3 You must not display materials while attending virtual meetings that other people might reasonably find offensive or use language which other Members, staff, tenants or customers might reasonably find offensive.
G	Relationship between Members and between Members and Staff
	Main Principle
	Members must maintain a constructive, professional relationship based on a sound understanding of their respective roles.
	Provisions
	G1 You have a duty of loyalty and support towards the Company and this must be reflected in a constructive, professional relationship with its staff. G2 You must not go beyond your role as a Member of STAC and become inappropriately involved in operational matters. G3 In your dealings with staff, formally and informally, you must set an example by demonstrating the highest standards of integrity and ethics and your alignment with the values, policies and objectives of the Company. G4 Where it is necessary to raise issues of poor staff performance at a formal meeting, these must be raised in a constructive way, aimed at getting things right in future, and not at criticising individuals. Any concerns about the performance of individuals must be discussed in confidence with the Chair of the Board, Committee or Panel, or with the Chief Executive. G5 You must not appear to undermine the authority of a senior officer in his or her dealings with a more junior member of staff. G6 You must avoid inappropriate personal familiarity with members of staff. Any relationships must be declared to the Company Secretary G7 You must not ask or encourage a member of staff to act in any way which would conflict with compliance with this Code of Conduct or the Company’s policies and procedures.
H	Relationship with tenants and other service users
	Main Principle
	You must maintain high standards of professionalism, fairness and courtesy in all your dealings with tenants and other service users.
	Provisions
	H1 You must treat all tenants and other service users with courtesy and respect. H2 You must not allow any personal relationship with a tenant or other service user to conflict with your role and responsibilities. H3 You must not give gifts or loans of money to, or receive loans or gifts of money from, tenants or other service users. H4 You must not invite or influence a tenant or other service user to make a will or trust under which you are named as executor, trustee or beneficiary. H5 When handling information relating to residents and other service users, you must comply with the law and the Company’s policies and procedures relating to the protection of personal data.
I	Health, Safety and Security
	Main Principle
	Your conduct must not endanger the health, safety or security of yourself or others.
	Provisions
	I1 You must comply with the Company’s health and safety policies and procedures and bring to the attention of the appropriate person any risks to yourself or others. In particular: Where you are provided with protective clothing this must be worn; andFor your own safety, you must comply with the Company’s policy and procedures relating to lone working. I2 You must comply with the law and the Company’s policies on smoking and on the use of alcohol, illegal drugs and other substances. I3 You must comply with the Company’s policies relating to the security of premises. I4 You must ensure that you are aware of your obligations as a Member in relation to health and safety.
J	Conduct at meetings
	Main Principle
	Your conduct at meetings must show respect for all and comply with the Company’s standards.
	Provisions
	J1 You must be courteous to all other attendees and respect the position of the meeting chair. J2 You must not use threatening or aggressive behaviour, or act in a disruptive way. J3 You must not attend meetings while intoxicated or under the influence of drugs. J4 Once a Board, Committee or Panel meeting has properly reached a decision, you must share responsibility for that decision, even where you had not supported it. J5 You must attend Board and Committee (as may be the case) meetings regularly.
K	Representing the Company
	Main Principle
	In representing the Company at external events and in dealings with outside bodies, you are an ambassador for the Company and must uphold and promote its values, objectives and policies.
	Provisions
	K1 You must not become involved in, or be seen to endorse, any activity that may bring the Company into disrepute. This includes but is not limited to illegal, immoral, racist or other discriminatory activity. K2 In engaging in activities which promote the work of the Company to the outside world, you must demonstrate commitment to the Company and support for its values, policies and goals. K3 In representing the Company at formal or informal events, you must be appropriately dressed for the occasion.
L	Learning and Development
	Main Principle
	In partnership with the Company, you must take responsibility for your own learning and development, regularly updating and refreshing your skills and knowledge.
	Provisions
	L1 You must play an active part in the Company’s supervision and performance appraisal process and welcome constructive feedback. L2 At the appropriate induction, appraisal or supervision meeting, you must make clear your personal training and development needs, so that they can be taken into account in the Company’s forward budgeting and planning. L3 Unless there are exceptional reasons, you must attend all learning and development events that have been arranged, either for you alone or as part of a group. L4 You must take responsibility for keeping your knowledge up to date in those areas in which you are a specialist.
M	Reporting concerns
	Main Principle
	You must report to the appropriate senior person within the Company any reasonable and honest suspicions you may have about possible wrongdoing.
	Provisions
	M1 If you are aware of potentially dishonest or fraudulent activity, or material breaches of this Code of Conduct by Members or others – you must report it to the Company Secretary. The Company’s policies and procedures relating to fraud and confidential reporting (whistleblowing) give further guidance. M2 If you believe that you are being required to act in a way which conflicts with this Code of Conduct, you must report it to the Company Secretary. M3 You must not victimise any person who has used – or intends to use or is suspected of having used – the Company’s confidential reporting procedures to report the misconduct, or alleged misconduct, of others.
N	Breaches of this Code of Conduct
	N1 Members should recognise that failure to follow this Code of Conduct may damage the Company’s reputation and its work and so will be viewed as a disciplinary matter. N2 N3 Actual or potential breaches of the Code of Conduct or any other complaints against Members will be investigated by the Chair and the Chief Executive. Actual or potential breaches of the Code of Conduct or any other complaints against the Chair will be investigated by the Chair of the Audit and Risk Committee and the Chief Executive. N4 Members under investigation for breach of the Code of Conduct will be notified of the enquiry and invited to present an explanation for their behaviour or actions. The Chair of the Board and Chief Executive (or Chair of Audit and Risk Committee and Chief Executive in the case of the Chair of the Board) will decide on whether to convene a Disciplinary Panel or whether some other action is more appropriate, including the issuing of an informal warning to the Member about their conduct. N5 The Chair of the Board (or Chair of Audit and Risk Committee in the case of the Chair of the Board) has the right to suspend the Member from their position until the conclusion of the investigation. They will convene a Panel of three Board Members to hear the case which they will present by way of written and oral report to the Panel. The Member will have the right of written and oral representation to the Panel meeting; they may be supported by a Member colleague or family member. Legal representation is not permitted. N6 Any Member breaching this Code of Conduct may only be expelled from the Company by resolution of at least two thirds of the Board. Depending on the outcome of the Panel hearing the Chair of the Board and Chief Executive (or Chair of Audit and Risk Committee and Chief Executive as appropriate) will prepare a report for the next Board meeting setting out the nature of the breach of the Code of Conduct, summary of the Panel’s findings, and any recommended sanction. N7 The report will provide the Member the opportunity to present any justifications to the Board in writing should they wish to remain in office. They may not attend the meeting whilst the Board considers that item and reaches its decision. N8 The Board’s decision will be conveyed to the Member orally within 24 hours and in writing within three working days.
O	Members Removal from STAC
	O1 Whilst this Code of Conduct has highlighted areas where Members may be expelled from office for breaches of the code or other serious matters, Members should also be aware that their appointment will immediately cease in the following circumstances: resigns his/her office by written notice to the Organisation; orshall for more than six consecutive months have been absent without permission of STAC from meetings of the Committee held during that period in any period of 12 months, he/she shall have been absent (without the permission of the STAC) from at least 60% of the meetings of STAC he/she ceases to be a Tenant PROVIDED THAT this shall not apply in respect of a Tenant temporarily ceasing to be a Tenant as a result of the demolition of or works carried out to that Tenant home; oris a Tenant Board Member and is in serious breach of his/her obligations as a Tenant
P	Acceptance
	P1 All new Members upon appointment will be expected to sign the Members Agreement for Services and associated documents including the Member Role Description and Person Specification, and this Code of Conduct. P2 Members are expected to refer to these documents during their term of office and remain familiar with their contents. P3 Any future changes once agreed by the Board, are deemed to have been accepted by all serving Members.
	Signed by: (You Member) NAME Signed by: (On behalf of the Company) NAME