Code of Conduct

1. Introduction

1.1. This Code of Conduct is linked to our Colleague Relations Framework and is for employees and for those working on our behalf. This includes employees (including agency workers), self-employed contractors, interns, Board and Committee Members / co-optees (including those of our subsidiary Boards) and Officers (as defined by our Rules).

1.2. A separate Code of Conduct is available for suppliers of goods and services to us (a copy is available on our intranet and website). We also have a Volunteering Code of Conduct setting out the values, rules, standards, and principles outlining what the expectations are for members of our Residents’ Forum, Focus Groups and our Task and Finish Group. It has been designed with our residents to make sure everyone is treated fairly: Volunteer Code of Conduct https://www.fairhive.co.uk/volunteer-code-of-conduct.

2. Policy Statement

2.1. Our residents, communities, stakeholders and the general public are entitled to expect the highest standards of conduct from those working on our behalf.

2.2. Our Board want you to feel engaged with the organisation and be advocates for its work and our residents. This Code of Conduct sets out the behaviours expected from you and puts in place protections for you.

2.3. You are expected to follow the code at all times, including whilst visiting resident homes, whilst off duty but identifiable as working for us (by driving a branded vehicle, for example) and whilst online, including social media, blogs and websites.

2.4. This Code of Conduct is based on the following seven principles to maintain the highest ethical standards[1]. We expect our employees to follow these principles:

Selflessness: to take decisions solely in terms of our vision and values and not in order to gain financial or other material benefits for employees, family or friends.
Integrity: not to place ourselves under any financial or other obligation to outside individuals or organisations that might influence the performance of our duties.
Objectivity: to ensure impartiality in the delivery of services, the appointment of employees, or the awarding of contracts and that choices are made on merit alone.
Accountability: to accept accountability for our decisions and actions towards our residents, colleagues, providers of public funds and other stakeholders and to submit ourselves to whatever scrutiny is appropriate.
Openness: to be as open as possible about all the decisions and actions that we take. We should give reasons for our decisions and restrict information only when individual or commercial confidentiality demands.
Honesty: to declare any private interests relating to duties and to take steps to resolve any conflicts arising in a way that is lawful and protects our reputation, values and purpose.
Leadership: to promote and support these principles by leadership and example.

2.5. We also fully endorse the standards set out in the National Housing Federation’s Code of Conduct 2026 (a copy is available in Fairhive Documents). This Code has five main expectations, which are:

Acting in the best interests of our residents and Fairhive: you have a responsibility to carry out your role in a way that supports the long-term interests of current and future residents and in line with our social purpose and values.
Behaving with integrity: you must act honestly, transparently and in line with the highest standards of ethical conduct. Our reputation and good name depend on compliance with this code, and with the laws, policies and procedures that it refers to.
Treating others fairly, with respect and empathy: the way in which people behave towards each other is fundamentally important to the experience of our residents and employees. Respectful, fair and empathetic behaviour is essential to building trust, maintaining effective relationships and supporting a healthy organisational culture.
Taking responsibility for the impact of your actions: you have a responsibility while working for Fairhive to consider the immediate and longer-term impact of your actions and to be accountable for them.
Acting with diligence and care: the diligence and care with which roles are performed has a significant impact upon the quality of decision making and services, and on the experience of residents and employees. This includes taking responsibility for your own performance and for meeting relevant professional standards.

2.6. We have other frameworks applicable to employees, for example, the Financial Controls Framework which all set out procedures for dealing with financial and contractual matters. These are available on our intranet

2.7. You must ensure that funds and resources entrusted to you, are used for the purpose intended and in a responsible and lawful manner. You should seek to safeguard such funds and resources from abuse, theft and waste and should strive to ensure value for money.

2.8. All gifts and hospitality should be logged in the Gifts and Hospitality Register, which is held by the Company Secretary. The Audit and Risk Committee review entries regularly.

2.9. You must, in the course of your employment or involvement with us:

Have regard to our reputation and interest at all times.
Strive for the highest standards of care and attention to your work.
Work within the law and comply with statutory and regulatory responsibilities.
Respect the confidentiality of information obtained in the course of your work and be aware of your responsibilities under data protection legislation as set out in our Data Protection and Data Retention Policy.
Be aware of, and work towards, our overall policy objectives.
Never abuse your position by accepting inducements or bribes or otherwise behaving dishonestly.
Ensure that all dealings with Board Members, other employees, our residents, our contractors, our stakeholders and the general public are carried out in a courteous and helpful manner.

We expect you to carry out your duties in accordance with all of our policies and procedures that are in place at any time, i.e. the Health and Safety Policy, the Equality, Diversity and Inclusion Policy etc. You are expected to uphold our values in the workplace as set out in our Success Factors and maintain high standards of personal conduct, courtesy, efficiency, sobriety, honesty and timekeeping.

3. Policy Outlines

3.1. Declaration of Interests

3.1.1. A conflict of interest is when a personal interest – family, friendships, financial or social could compromise your judgement, decisions or actions in the workplace. This can relate to any situation in which you are in a position to take advantage of a professional or official capacity, in some way, for your personal or company benefit. It occurs where an individual’s ability to exercise judgement or act for the benefit of one role is, or could be, impaired or otherwise influenced by their personal or professional involvement in another role or relationship. The individual does not need to exploit their position or obtain an actual benefit, financial or otherwise.

3.1.2. A conflict of interest may be:

3.1.2.1. Actual – there is a material conflict between one or more interests.

3.1.2.2. Potential – there is the possibility of a material conflict between one or more interests in the future.

3.1.3. Employees/Officers/Board & Committee Members may hold interests for which they cannot see potential conflict. However, caution is always advisable because others may see it differently and perceived conflicts of interest can be damaging. All interests should be declared where there is a risk of perceived improper conduct.

3.1.4. Interests may fall into the following categories:

3.1.4.1. Financial interests – where an individual may receive direct financial benefit from the consequences of a decision they are involved in making.

3.1.4.2. Non-financial professional interests – where an individual may obtain a non-financial professional benefit from the consequences of a decision they are involved in making such as increasing their professional reputation or promoting their professional career.

3.1.4.3. Indirect interest – where an individual has a close association with another individual who has a financial interest, a non-financial professional interest or a non-financial personal interest and could stand to benefit from a decision they are involved in making.

3.1.5. We are committed to the principles of openness and transparency in relation to the declarations of interest process. All employees, Board & Committee Members must complete a Declaration of Interest Form annually, (please see Appendix 1 for the employee form and Appendix 2 for the Declaration of Interest Form for our Board & Committee Members), to declare any potential conflict(s) of interest relating to your close relations (including any relationship, not just by blood or marriage) and any business trading for profit with which you are connected. You must disclose any membership which may give rise to a conflict of interest with your duties to us. Conflicts will be raised with our Executive Leadership Team (ELT) who will consider how best to manage the potential conflict for employees.

3.1.6. Our Declaration of Interest Form will be sent out annually at the end of every financial year. Our People Management Team manage the completion process and a central register of positive declarations is managed by our Assistant Director of People and Head of Governance. Our ELT and Chief Executive review all positive declarations of interests in their area of responsibility. A summary report of positive declarations of interests is shared annually with our Board. Our line managers will support this process to ensure all declaration of interest annual returns are completed.

3.1.7. In the event that you believe that a potential conflict of interest has arisen part way through the annual cycle, detailed in paragraph 3.1.6, you should obtain and complete a Declaration of Interest Form (available on our intranet) in order to make an ad-hoc declaration. Any such ad-hoc declarations will be dealt with in the same way as annual declarations.

3.1.8. Managers that are procuring goods and or services should ensure that their department maintains records that show a clear audit trail of how conflicts of interest have been identified and managed as part of procurement processes. They will also invite all employees taking part in each tender exercise to declare their interests at the start of the procurement process and ensure that those records are maintained and are made available within 28 days of the procurement exercise commencing.

3.1.9. No company, which may bid for business, should be given any advantage over its competitors, such as advance notice of requirements. This applies to all potential contractors. No steps should be taken to encourage the application of any contractor or any representations made alluding to more favourable terms. Scrupulous care must be taken to ensure that the selection process is conducted impartially and that employees who are known to have a relevant interest play no part in the selection process.

3.1.10. Individuals who have concerns regarding a conflict of interest or ethical misconduct, either in respect of themselves or colleagues, should raise it using the Confidential Reporting (Whistleblowing) Policy. Where an employee, Board or Committee Member has failed to disclose any relevant interests or has otherwise breached our policies and procedures in relation to failing to disclose, they will be subject to investigation and where appropriate, to disciplinary action and potential dismissal in accordance with our Disciplinary Policy and/or Anti-Fraud, Bribery and Corruption Policy. It is an offence under the Fraud Act 2006, to fail to disclose information to the organisation in order to make a gain for yourself or another. It is also an offence to cause a loss or expose the organisation to a loss. Reports on breaches, the impact of these and action taken will be considered by the Audit and Risk Committee on a periodic basis.

3.1.11. Individuals applying for Board, Committee and Resident Forum roles will complete a Declaration of Interest Form prior to appointment. Any conflicts declared will be taken into account as part of the recruitment process.

3.2. General

3.2.1. Employees should not engage in an additional form of employment nor engage in business activities which could overlap and conflict with our interests. You must seek prior approval from the Chief Executive for all outside paid employment, regular volunteering or business activities. This can be sought by completing the form in Appendix 3. You should confirm the total number of working hours and whether it exceeds, on average, 48 hours per week, in accordance with the Working Time Regulations 1998 (for more information, please see “maximum weekly working hours” on www.gov.uk).

3.2.2. When applying for employment with us or newly employed, you are required to disclose any interest which could lead to a conflict of interest as soon as possible following a start date.

3.2.3. Engaging in other work when claiming occupational sick pay, or working for another organisation during the hours you are employed by us, may be considered a breach of the Code of Conduct and result in an investigation in accordance with the Anti-Fraud, Bribery and Corruption Policy to consider whether this constitutes a criminal offence. If so, this may result in prosecution under the Fraud Act 2006. In either case, a breach of this kind may result in disciplinary action which may include dismissal for gross misconduct and/or referral to a professional body.

3.2.4. Although our work may involve public affairs, we do not have a political position or support a specific party. You should keep personal political activities separate from your work and should ensure that our reputation is not damaged by your personal activities or affiliations. We do not make contributions to political parties.

3.2.5. We expect our employees to be respectful to the beliefs and opinions of others. This includes refraining from trying to influence others to adopt your political, religious or other held beliefs. We aim to work in ways that seek support and enable our employees and residents to make their own decisions and choices, even if we may disagree or hold a different view. We are committed to Equality, Diversity and Inclusion and will appropriately challenge and manage anything that conflicts with this, so we comply with legislation and Charity Commission guidance. Employees are referred to our Equality, Diversity, and Inclusion Policy for further information.

3.3. Anti-Fraud and Corruption

3.3.1. Our Board is committed to the prevention, deterrence, detection and investigation of all forms of fraud, bribery, theft and corruption and applies a zero tolerance in all cases.

3.3.2. As an organisation, we have a duty to ensure that all our dealings are conducted to the highest standards of integrity. As such and as set out in the Anti-Fraud, Bribery and Corruption Policy, we have a zero-tolerance attitude towards fraud and bribery. Circumstances around gifts, hospitality and interests could be considered a bribe and all employees should consider this in all actions involving gifts, hospitality or interests to protect themselves and the organisation from criminal prosecution.

3.3.3. The corporate offence under the Bribery Act 2010 means that commercial organisations will be exposed to criminal liability and punishable by an unlimited fine for failing to prevent bribery in the conduct of their business. It is therefore our policy to conduct all of our business in an honest and ethical manner, implementing and enforcing effective systems to prevent bribery.

3.3.4. We are required to maintain proportionate, adequate procedures to mitigate the risk of bribery, in accordance with the Bribery Act 2010. This includes the appropriate management of gifts, hospitality, sponsorship and interests and is applicable to all persons associated with the organisation, as outlined in this policy. We fully support compliance with this Act and further information can also be found in the Anti-Fraud, Bribery and Corruption Policy.

3.3.5. This Act is not intended to prevent genuine hospitality or similar business expenditure that is reasonable and proportionate, so organisations can continue to fund bona fide hospitality and promotional activity. However, it is expressly prohibited for an employee to accept any gift or benefit from an organisation that is actively involved in a tender process with us.

3.3.6. It is an offence under the Bribery Act 2010 for an individual to corruptly accept any inducement or reward for doing, or refraining from doing, anything in their official capacity or corruptly showing favour or disfavour in their handling of contracts.

3.3.7. Potential contractors should be warned through the tender document, that contractors will be expected to comply with our policies whilst carrying out business for us. This will include a notice warning contractors of the consequences of engaging in any corrupt practices. Employees must not offer any inducements or rewards to tenderers or applicants.

3.3.8. We seek to conduct our business in an honest and ethical manner and to this end employees must:

3.3.8.1. Separate their private purchasing from that of the organisation to avoid suspicion of preferential treatment by suppliers.

3.3.8.2. Declare to their ELT Director or Assistant Director, preferential rates offered in any private transaction with a supplier due to our relationship with that supplier that falls outside of any special terms negotiated for all employees.

3.3.8.3. Not use our order forms, headed notepaper and other formal documents to obtain private goods or services, even when reimbursement is made to us. The same applies to personal transactions made using the internal or external email.

3.3.9. You must always avoid disclosing any confidential or commercially sensitive information, e.g. the tender position of a company. Prices offered to us as a company, for contracts, goods or services, must not be disclosed to any outside contractors.

3.3.10. Invitations to contractors to tender for business should be made in accordance with approved financial regulations and contract standing orders.

3.3.11. Employees are expected to use facilities and equipment provided, properly and in connection with business undertaken on our behalf. All employees, Board and Committee Members should be familiar and comply with our policies which include the Anti-Fraud, Bribery and Corruption Policy, the ICT Acceptable Use Policy and our Data Protection Policy.

3.4. Gifts, Hospitality and Donations

3.4.1. Please be aware that gifts or hospitality may be used as a subterfuge for bribery. This should be considered in all circumstances in order to protect yourself and the organisation from criminal prosecution.

3.4.2. All gifts from contractors or suppliers above £10 must be politely but firmly declined, with an explanation that it is not our policy to accept gifts. Low cost branded promotional aids such as pens or post-it notes may, however, be accepted where they are under the value of £10 in total and need not be declared.

3.4.3. You should not accept gifts or hospitality that may affect, or be perceived to affect, the outcome of a business transaction, nor accept any gift or benefit from an organisation that is actively involved, or likely to be, in a tender process with us. In addition, you may not ask for gifts, entertainment nor hospitality and will not give nor receive repeated or lavish entertainment or hospitality.

3.4.4. You may not receive any payment, grant or loan from any funds associated with us, except provided for under your contract of employment/Agreement for Services or as a re-imbursement for legitimate expenses.

3.4.5. Except as outlined below, you are not allowed to accept personal gifts, goods nor services from residents, consultants, contractors or other agents employed directly by us or seeking such employment. Any gifts, goods, services or extravagant entertainment (received or given) which could be seen to influence judgement or decisions are absolutely prohibited. All should be refused/returned with an explanation that it is not our policy to accept gifts, and notified to their ELT Director or Assistant Director, or the Company Secretary and recorded in the Gifts and Hospitality Register held by the Company Secretary.

3.4.6. You are not permitted to offer, promise, give, request or accept bribes or inducements under any circumstances. If you are offered a bribe or asked to make one, or if you suspect that bribery or corruption has occurred or may occur you should report your concerns using the Confidential Reporting (Whistleblowing) Policy or Anti-Fraud, Bribery and Corruption Policy.

3.4.7. Hospitality, gifts and entertainment should be avoided by those who are directly involved in a tender process or where a development scheme is pre-contract with a bidder/potential partner.

3.4.8. Hospitality must only be accepted when there is a legitimate business reason, and it is proportionate to the nature and purpose of the event. Particular caution should be exercised when hospitality is offered by actual or potential suppliers or contractors. This can be accepted, and must be declared, if modest and reasonable. Hospitality is prohibited whenever it could affect, or be perceived to affect, the outcome of a business transaction. Hospitality which is offered on a personal basis to a particular individual should be treated with caution. You should always obtain the prior approval from your Executive Director or Assistant Director or in the case of Board & Committee Members, the Company Secretary before accepting offers of hospitality, before attending evening events, venues, business lunches, overnight hospitality or purely social or sport connected functions with existing or potential contractors. Executive Directors and Assistant Directors should seek the Chief Executive’s prior approval. Any acceptance of hospitality events needs to include the rationale and outcome of attendance i.e., networking opportunity, new learning, exploring new avenues and opportunities for our organisation. You must enter all hospitality in the Gifts and Hospitality Register, held by the Company Secretary.

3.4.9. Gifts with a value of £10 or less may be accepted, provided it is clear that it will not influence any judgement or decision. No gift of money or its equivalent should be accepted, regardless of the amount. All gifts and refused gifts with a value of £10 or more must be recorded in the Gifts and Hospitality Register, held by the Company Secretary. A common-sense approach should be applied to the valuing of gifts (using an actual amount, if known, or an estimate that a reasonable person would make as to its value). Multiple gifts from the same source over a 12-month period should be treated in the same way as single gifts over £10 where the cumulative value exceeds £10.

3.4.10. If there is any concern over the appropriateness of a gift, hospitality or entertainment the following steps should be taken:

Is the activity necessary for business purposes e.g. gathering market intelligence?
Is the activity likely to be considered an incentive or given with the intention of influencing a decision or outcome or to reward improper performance, in which case advice should be sought that it does not fall within the Bribery Act 2010?
Is it proportionate to the individual’s role within the company and the supplier’s relationship to us?

If in doubt, advice should be sought from your Executive Director or Assistant Director and you may need approval from the Chief Executive. If refusing a gift could cause offence, authorisation may be given for the gift to be collected centrally on our behalf and donated to our Charity of the Year.

3.4.11. Senior Managers may give occasional, modest hospitality with prior approval from their Executive Director or Assistant Director. In all cases this is limited to:

Modest working meals and light refreshment.
Reciprocation of modest invitations for meals.
Small gifts in relation to voluntary services e.g. guest speakers.

All gifts and hospitality of a value of £10 or more must be declared in the Gifts and Hospitality Register, held by the Company Secretary.

3.4.12. If in doubt, advice should be sought from the Chief Executive.

3.4.13. Donations made by suppliers or bodies seeking to do business with the organisation should be treated with caution and not accepted. In exceptional circumstances, if an employee believes that it is appropriate or necessary to accept a donation of this type, they may be accepted but should always be approved in advance by an Executive Director or Assistant Director and declared. A clear reason should be recorded as to why it was deemed acceptable, alongside the actual or estimated value. Employees should not actively solicit charitable donations unless this is a prescribed or expected part of their duties. Donations, when received, should be recorded, including the name of the donor, and payment should be made to the company (never direct to an employee).

3.4.14. We have a modest budget for charitable donations, which is allocated through the Giving Something Back scheme.

3.4.15. No gift or hospitality that may amount to or cause the recipient or giver to commit a criminal offence can either be given or accepted. Take care not to accept or give a gift or arrange or accept hospitality that could cause offence to others or damage our reputation.

Relationships with Residents and Potential Residents

3.4.16. It is so important that our employees have the necessary skills, knowledge and experience and exhibit the behaviours needed, to ensure the services we provide are of good quality.

3.4.17. You should be professional and courteous in all your dealings with residents and other customers.

3.4.18. You should be especially careful in your relationships with residents. You should be mindful at all times of the way your conduct may be viewed and/or misrepresented. Any personal relationships must not conflict with the best interest of the resident concerned, or bring undue pressure to bear in matters concerning their rights as a resident.

3.4.19. A “personal relationship” refers to any romantic or emotional relationship beyond normally accepted professional boundaries.

3.4.20. Where a personal relationship exists between you and a resident, you are required to inform HR as soon as reasonably practicable and submit an ad-hoc Declaration of Interest Form. All reports will be handled confidentially. While there is no formal requirement, you should consider whether it may also be appropriate to inform your line manager, if for example, there is a risk of a conflict of interest or perceived conflict of interest arising. We will then liaise with those involved to agree a plan to minimise the impact of the personal relationship on the business. Failure to disclose a personal relationship to HR will be treated as a disciplinary matter and, subject to investigation, could result in disciplinary action, up to and including dismissal.

3.4.21. In the delivery of services, you should be mindful of your responsibilities to the residents and communities that you serve and ensure courteous, efficient and impartial service delivery to all groups and individuals.

3.4.22. Employees involved in the award of tenancies or allocation of housing must ensure absolute impartiality in the decisions made and avoid any conflicts of interest. Employees must not be involved in the awarding of tenancies whereby they have a personal relationship with the individual. There is also a requirement for this relationship to be declared, as above.

3.4.23. Where a manager becomes aware that a member of their team is in a personal relationship with a resident, they are required to treat this sensitively and, as far as possible, in confidence, and guidance should be sought from HR. They should ensure that a formal note is taken of any meetings to discuss personal relationships. Managers are reminded of their obligations under the law and our Data Protection and Data Retention Policy, Sexual Harassment Policy and Bullying and Harassment Policy.

3.4.24. You must never allow yourself to be compromised by, nor take advantage of, your relationship with residents. The relationship of trust must never be abused.

3.4.25. Our rules in relation to confidentiality continue to apply regardless of any personal relationship.

3.4.26. Nobody will be disadvantaged, discriminated against or otherwise subjected to a detriment because they are in a personal relationship. Any employee who has concerns about their treatment should raise this informally with their line manager in the first instance, or otherwise use the formal grievance procedure.

3.4.27. The handling of money belonging to residents should be avoided. If there is no alternative, extreme care should be taken and any transaction must be properly receipted and recorded in accordance with our policies and procedures. Payment of rent in cash must not be accepted from a resident unless it is in exceptional circumstances to avoid an imminent eviction and the acceptance of cash in such a situation must be witnessed by two other employees and receipted accordingly. The cash must be stored in the safe at Fairfax House and banked as soon as possible thereafter, with two employees undertaking the exercise. The timeline of accepting, receipting and banking the cash must be clearly documented on the account it is relating to.

3.4.28. You must not invite nor influence a resident nor other service user to make a will or trust under which you are named as an executor, trustee or beneficiary. You must not accept any nomination from a resident nor other service user to be included in their will or trust.

3.5. Relationships at Work

3.5.1. You should be mindful at all times of the way your conduct may be viewed and/or misrepresented. Unwanted attention may be perceived as harassment and can potentially be a breach of the law.

3.5.2. You must never allow yourself to be compromised by, nor take advantage of, your relationship with colleagues. The relationship of trust must never be abused.

3.5.3. Any personal relationship must not conflict with our best interests or our employees, or bring undue pressure to bear in matters concerning their employment rights.

3.5.4. A “personal relationship” refers to any romantic or emotional relationship beyond normally accepted professional boundaries between colleagues. This applies to all personal relationships between any employees, regardless of whether those involved work in the same team, department, division or office, or at the same site.

3.5.5. Any personal relationship must be conducted with discretion and dignity. They must be kept separate from work relationships. You should ensure that your relationship does not affect other colleagues, work standards or our culture or reputation.

3.5.6. No employee will directly manage another employee who is a family member or with whom they are in a personal relationship. In the event of such a situation arising, the parties are required to inform a member of the Senior Management Group or HR and submit an ad-hoc Declaration of Interest Form. We will then liaise with those involved to agree a plan to minimise the impact of the personal relationship on the business.

3.5.7. Failure to disclose a personal relationship as required by this policy will be treated as a disciplinary matter and, subject to investigation, could result in disciplinary action, up to and including dismissal.

3.5.8. All employees are reminded that they are subject to our polices and procedures, including our Equality, Diversity and Inclusion Policy, Bullying and Harassment Policy, Sexual Harassment Policy, Data Protection and Data Retention Policy, and our policies relating to confidentiality. Breach(es) of these policies may result in disciplinary action, up to and including dismissal.

3.5.9. Given the sensitive nature of personal relationships, managers should seek the assistance of HR before dealing with any issues which may arise.

3.6. Conduct at Board, Committee and Internal Meetings

3.6.1. If employees are present at a meeting that is discussing any item which poses a conflict of interest, they should declare the interest. If the conflict is clear and substantial, they should leave the meeting.

3.6.2. Employees must treat all others with respect and consideration at all times. As a result, all meetings should be professional.

3.6.3. Declarations of Interest will be a standing agenda item at any formal Governance meeting before consideration of new business. Those attending are under obligation to raise any interests they may have in relation to the agenda and a decision will be made, in accordance with our rules, as to whether it is appropriate for them to participate in the meeting.

3.7. Employment Matters

3.7.1. Close relatives of existing employees and employees who have left within the last twelve months can only be employed by the organisation through our normal open recruitment process and the applicant must prove that they fulfil the person specification and are the best person for the job.

3.7.2. In order to avoid any possible accusation of bias, you are not permitted to be part of the recruitment process for individuals with whom you have a personal relationship outside work or if you are related to an applicant. Any such relationship should be declared, whether or not you are involved in the recruitment process. This extends to the shortlisting, interviewing, appointing, promoting and review of performance or termination of employment or appointment as a Board or Committee Member.

3.7.3. Similarly, you should not be involved in any decision relating to discipline, performance management, pay, promotion etc. for any employee who is a relative, partner or close personal friend.

3.7.4. If you, or your family, are our residents, you/they must not use your/their position to gain advantage, information nor preferential treatment.

3.8. Confidentiality

3.8.1. All our employees, Board and Committee Members should be aware of their responsibilities regarding matters of a private and confidential nature.

3.8.2. You must treat the following as confidential:

Information about individuals, including residents, employees, applicants or anyone connected to our services
Commercial or business information that is not publicly available.
Any information covered by data protection legislation.
Information relating to funders, partners or referral agencies.

When sharing data you must always follow our Data Protection and Data Retention Policy.

All information must be kept secure at all times, including when working remotely, in line with our ICT Acceptable Use Policy.

Under no circumstances should confidential information be discussed or disclosed to anyone who is not authorised to receive it.. All queries such as specific requests from the statutory authorities should be processed by an Executive Director or Assistant Director.

Any breach of confidentiality may result in disciplinary action being taken.

3.8.3. This duty continues after you have left our employment or the Board, Committee or Forum on which you served.

3.9. Using Artificial Intelligence (AI) at Fairhive

3.9.1 We support the responsible use of AI to help employees to work more efficiently, but it must always be used safely, ethically and with human oversight.

3.9.2 Employees may use Microsoft Copilot (logged into your business account) to support tasks such as drafting, summarising or generating ideas, however you are always responsible for checking and approving the final output.

3.9.3 When using AI you must:

Protect personal and sensitive data at all times
Use AI in a fair and non-discriminatory way
Be transparent about its use where appropriate
Ensure outputs are accurate and suitable before use

3.9.4 To comply with UK GDPR and protect confidentiality:

You must not enter personal, resident, colleague, or sensitive information into any AI tool unless it has been specifically approved for secure use.
Public AI tools (such as ChatGPT or other unapproved systems) must not be used for work-related data – this includes Co-pilot's web option)
Co-pilot and approved tools should only be used within our secure systems.

3.9.5 AI must not be used to make fully automated decisions, such as shortlisting job applications or procurement bids, human oversight and judgement is always needed.

3.9.6 Any concerns about AI outputs, including accuracy, bias or data security must be reported immediately to the Head of IT Systems and Data.

3.10. Appearance and Dress Code

3.10.1. You represent us and this includes your appearance which can impact our reputation. These guidelines ensure we:

Promote a positive and professional image.
Respect the needs of people from all cultures and religions.
Make any reasonable adjustments that may be needed because of disability.
Take account of health and safety requirements; and
Help you and managers decide what clothing is appropriate to wear to work and when visiting resident homes.

3.10.2. When representing us it is important that you are presentable, particularly when you may be in contact with residents, business contacts or the wider communities we serve. This also applies to both face to face and during online meetings when working from home. Please ensure when visiting resident homes, you wear Fairhive identification such as your name badge / lanyard; this is a cornerstone of safety, trust and professionalism.

3.10.3. You are welcome to wear religious and/or cultural dress (including, for example, clerical collars, head scarves, skullcaps and turbans) unless it creates a health and safety risk or otherwise breaches our policies. Where necessary your manager or HR can give further information and guidance on cultural and religious dress in the workplace.

3.10.4. It is important that you dress in a manner appropriate to your working environment and the type of work you do. For example, in certain roles you may be required to wear uniforms or PPE, provided by us: these should be kept clean and in good repair. Workwear should be clean, smart/casual with no clothing rips nor tears and no slogans that could be misinterpreted, offensive or cause damage to our reputation.

3.10.5. Footwear must be practical and take health and safety considerations into account. For instance, appropriate footwear does not include flip-flops/sliders as the majority of slips and trips on stairs are caused by footwear of this type.

3.10.6. For any questions regarding our dress code, including whether an article of clothing is suitable for work, please speak to your line manager.

3.11. Social Media

3.11.1. The same high standards of conduct outlined in this document should be applied to any online communication.

3.11.2. Our social media channels are managed by the Communications and Partnership Team. Curatorship may be handed over to employees from time to time to enhance content and help tell our story. You may inject your personality into posts but remember to remain professional: if you wouldn’t say it face to face, don’t post it.

3.11.3. We encourage use of personal social media in line with the ICT Acceptable Use Policy, providing it does not affect your performance. You are our brand advocates, and your interactions with our online channels contribute to their success and can enhance our reputation. Be mindful not to share confidential information nor information only accessible by virtue of being an employee or your membership of a Board or Committee. Information or case studies not already in the public domain should not be shared via personal social media accounts.

3.11.4. You are accountable for whatever you put into the public domain on both your privately held account and our corporate pages. Do not post anything that may directly or indirectly bring us into disrepute or damage our business interest or reputation. You should not display offensive images, make offensive comments, or post anything that may harass, intimidate, bully, victimise or discriminate against us or others. Names and personal information should not be posted on social media nor used in comments unless you have explicit consent from the individual to do so. This applies to both personal and corporate pages.

3.11.5. Our logos or other copyrighted material may only be used with the knowledge and agreement of the Communication and Partnership Team.

3.11.6. Release of information regarding funding and finances must be limited to those authorised to do so to avoid unnecessary negative attraction e.g. cyber/phishing risks.

You should never use social media in a way that breaches any of our other policies. If an internet post would breach any of our policies in another forum, it would also breach them in an online forum. Any policy breaches will be subject to disciplinary action up to and including termination of employment.

3.12. Media Contact

3.12.1. If you are made aware of or pick up any negative media coverage about us, either in the press or on social media, or you receive a media contact or enquiry, please send it to pressoffice@fairhive.co.uk.

3.12.2. If you are made aware of a threat to go to the media, please report it to pressoffice@fairhive.co.uk immediately.

3.13. Time Recording (Employees)

3.13.1. In most roles, it is necessary for employees to time record their activities. Where relevant, training will be provided to employees by their line manager or the Employee Development Team.

3.13.2. When time recording, employees are required to accurately and honestly record all relevant details. Any attempts to falsify time records may be dealt with as gross misconduct under the terms of our Disciplinary Policy.

3.14. Court Attendance and Jury Service (Employees)

3.14.1. In court cases where you are requested to be witness, if the case is connected to us in any way, or we have requested you attend court, you will be fully paid for this time. For all non-company related court activity, you will need to take this out of your own time, via flexi-leave or holiday or as unpaid leave.

3.14.2. If you receive a summons to serve on a jury you must report this immediately to your line manager (copying in HR) who will ordinarily grant you leave of absence, unless exemption is granted. During your jury service you will continue to receive your salary in full to ensure minimum disruption to personal finances.

3.15. Health, Safety and Security

3.15.1. Your conduct, actions and decision making must promote the health, safety, security and wellbeing of yourself and others.

3.15.2. Your conduct must not endanger the health, safety and security of yourself or others.

3.15.3. You must comply with our Health & Safety and Lone Working Policies and Procedures, and those relating to smoking, the use of alcohol, illegal drugs and other substances.

3.16. Protecting the Environment

3.16.1. Within your role, you must strive to avoid or reduce possible negative environmental impacts.

3.16.2. In carrying out actions or making decisions in the performance of your role, you must consider the environmental impact of your decisions and where you are able, seek to achieve positive environmental outcomes.

3.17. Failure to Follow this Code

3.17.1. Failing to follow this Code of Conduct may damage our reputation or ability to carry out our business. Transgressions will be treated as potential gross misconduct and will be dealt with under the Disciplinary Policy.

3.17.2. This policy does not form part of any employees’ contract of employment nor Board/Committee Members’ Agreement for Services and we may amend it at any time.

4. Monitoring

4.1. The HR department is responsible for monitoring this policy and providing regular reports to the Assistant Director of People and by exception to the Executive Leadership Team. This policy will be reviewed at least every three years to ensure that it remains relevant to the business and fit for purpose.

4.2. As outlined in this policy, we will provide a reminder of policy requirements on an annual basis. Registers of interests, gifts and hospitality will be maintained and monitored. Our (internal and external) auditors will also monitor compliance with this policy and will report any findings to the Audit and Risk Committee.

4.3. Our Audit and Risk Committee is authorised by the Board to measure the reach, compliance and effectiveness of this policy on its behalf. This includes a mechanism for measuring the cumulative value of gift, hospitality or sponsorship offered by external parties. Should the Audit and Risk Committee have any concerns regarding compliance or management of the policy, these are raised to the Board.

4.4. Our Board is responsible for corporate decisions and therefore has a responsibility to ensure that conflicts of interest in business matters are avoided, and that there is a mechanism for recognising, reporting and dealing with potential conflicts.

4.5. All declarations of interest will be monitored by the organisation.

4.6. It is noted that we are no longer required to undertake an annual assessment of compliance with our Code of Conduct; however, breaches will be reported to the Remuneration & Selection Committee and Board.

5. Impacts

Resident/Employee Implications -

This Code of Conduct is for employees, Board and Committee Members. Also for those working on our behalf . This includes contractors, sub-contractors and agency workers. This Code of Conduct has been reviewed by our Resident Policy Collaboration Group.

Impact on Service Delivery -

This policy supports employees and those involved in Governance decisions by ensuring standards are clear and issues are addressed in a fair and timely manner.

Equality, Diversity and Inclusion -

This policy is applied to all in a fair and consistent manner, and conforms to the requirements of the Equality Act 2010.

This policy will help manage any forms of unacceptable behaviour.

Value for Money -

Policies that provide for effective behaviour management reduce time spent both by managers and HR in addressing employee relations issues or employee related legal matters.

Data Protection -

All data is stored in line with our Data Retention Policy.

Regulation Framework/Code of Governance -

Part of the HR Framework.

Risks -

There is a risk of an unpleasant working environment if unacceptable behaviour is not managed as per this policy, or if individuals involved with us feel unable to safely raise concerns.

Many of the elements of the Code of Conduct are based on legislation – failure to comply could risk a breach.

Health and Safety -

This policy reminds employees of their expected conduct in relation to health and safety at work.

Financial -

We depend on motivated and engaged employees to deliver our strategic objectives.