Penlee Cluster Staff Code of Conduct

Aims, scope and principles

This policy aims to set and maintain standards of conduct that we expect all paid staff to follow.
By creating this policy, we aim to ensure our churches and church schools are an environment where everyone is safe, happy and treated with respect.
Paid Staff have an influential position in the community and will act as role models for people by consistently demonstrating high standards of behaviour.
We expect that all paid staff will act in accordance with the personal and professional behaviour.
We expect all paid staff to also act with personal and professional integrity, respecting the safety and wellbeing of others.

Penlee Cluster of Churches
Our aims are based around 4 key statements as expressed in the ‘Deeply Christian, Serving the Common Good’ document:

  • Educating for Wisdom, Knowledge and Skills by offering activities that stimulate a sense of curiosity and excitement about the world whilst developing the full potential of all people.
  • Educating for Hope and Aspiration by providing a safe, nurturing and caring environment where all people can take risks, build resilience, flourish and demonstrate courageous advocacy in action.
  • Educating for Community and Living well together by building positive relationships with our local, national and international communities making a positive difference to all people .
  • Educating for Dignity and Respect by promoting perseverance, generosity, and courage for all.

We expect all paid staff to live out these ideals which support our staff code of conduct.
Failure to follow the code of conduct may result in disciplinary action being taken, as set out in our staff disciplinary procedures.
Please note that this code of conduct is not exhaustive. If situations arise that are not covered by this code, paid staff will use their professional judgement and act in the best interests of all.

Legislation and guidance

In line with the statutory safeguarding guidance Keeping Children Safe in Education and the mandatory diocesan Safeguarding Training this code of conduct, which should cover low-level concerns, allegations against staff and whistle-blowing, as well as acceptable use of technologies (including the use of mobile devices), young people’s relationships and communications, including the use of social media.

General obligations

Paid Staff set an example to all by:

  • Maintain high standards in their attendance and punctuality
  • Never use inappropriate or offensive language in church contexts
  • Treat everyone and others with dignity and respect
  • Show tolerance and respect for the rights of others
  • Not undermine fundamental British values, including democracy, the rule of law, individual liberty, and mutual respect and tolerance of those with different faiths and beliefs
  • Not express personal beliefs in a way that exploits people’s vulnerability or might lead them to break the law
  • Duty of care to each other and others who may be affected by their activities.


Paid Staff have a duty to safeguard young people and vulnerable people from harm, and to report any concerns they have.
Paid Staff will familiarise themselves with our child protection and safeguarding policy and procedures, and the Prevent initiative, and ensure they are aware of the processes to follow if they have concerns about a child.
Our safeguarding policy and procedures are available on our website and in the church buildings. New staff will also be given copies when they begin work with us. Safeguarding is everyone’s responsibility.

Allegations that may meet the harm threshold

If someone has behaved …

  • in a way that has harmed or may have harm people
  • Possibly committed a criminal offence against or related to people
  • Behaved towards a child or vulnerable adults in a way that indicates they may pose a risk of harm to children and vulnerable adults
  • Behaved or may have behaved in a way that indicates they may not be suitable to work with young people or vulnerable adults and this includes behaviour taking place inside or outside events arranged by the Penlee Cluster

We will deal with any such allegation quickly and in a fair and consistent way that provides effective child protection while also supporting the individual who is the subject of the allegation.
A ‘case manager’ will lead any investigation.

Low-level concerns about members of staff
A low-level concern is a behaviour towards a young people or vulnerable adults by a member of staff that does not meet the harm threshold, is inconsistent with the staff code of conduct, and may be as simple as causing a sense of unease or a ‘nagging doubt’.
For example, this may include:

  • Being over-friendly with young people
  • Having favourites
  • Taking photographs of young people on a personal device without permission or authorisation for a specific reason
  • Engaging in 1-to-1 activities where they can’t easily be seen or not in accordance with our Lone Working policy
  • Humiliating children

Low-level concerns can include inappropriate conduct inside and outside of work.

All staff should share any low-level concerns they have using the reporting procedures set out in our child protection and safeguarding policy. We also encourage staff to self-refer if they find themselves in a situation that could be misinterpreted. If staff are not sure whether behaviour would be deemed a low-level concern, we encourage staff to report it to the lead person on duty.

All reports will be handled in a responsive, sensitive and proportionate way.

Unprofessional behaviour will be addressed, and the staff member supported to correct it, at an early stage.

This creates and embeds a culture of openness, trust and transparency in which our values and expected behaviour are constantly lived, monitored and reinforced by all staff, while minimising the risk of abuse.

Reporting and responding to low-level concerns is covered in more detail in our child protection and safeguarding policy and low level concerns policy.

Our procedures for dealing with allegations will be applied with fair judgement.


Whistle-blowing reports wrongdoing that it is “in the public interest” to report. Examples linked to safeguarding include:

  • Children, vulnerable adults or staff health and safety being put in danger
  • Failure to comply with a legal obligation or statutory requirement
  • Attempts to cover up the above, or any other wrongdoing in the public interest

Paid Staff are encouraged to report suspected wrongdoing as soon as possible. Their concerns will be taken seriously and investigated, and their confidentiality will be respected.

Paid Staff should consider the examples above when deciding whether their concern is of a whistle-blowing nature. Consider whether the incident(s) was illegal, breached statutory or school procedures, put people in danger or was an attempt to cover any such activity up.

Paid Staff should report their concern to the Team Leader. If the concern is about the Team Leader or it is believed they may be involved in the wrongdoing in some way, the staff member should report their concern to the safeguarding leads

Concerns should be made in writing or email/text wherever possible. They should include names of those committing wrongdoing, dates, places and as much evidence and context as possible. Staff raising a concern should also include details of any personal interest in the matter.

Interpersonal relationships

Paid Staff will observe proper boundaries with young people and vulnerable adults that are appropriate to their professional position. They will act in a fair and transparent way that would not lead anyone to reasonably assume they are not doing so.
If staff members and young people must spend time on a one-to-one basis, staff will ensure that:

  • This takes place in a public place that others can access
  • Others can see in to the room
  • A colleague or line manager knows this is taking place

Personal contact details should not be exchanged between staff and young people. This includes social media profiles.

If a staff member is concerned at any point that an interaction between themselves and a young person or vulnerable adult may be misinterpreted, or if a staff member is concerned at any point about a staff member and a young person, this should be reported in line with the procedures set out in our child protection and safeguarding policy.

Communication and social media

Staff’s social media profiles should not be available to young people or parents. If they have a personal profile on social media sites, they should not use their full name, as young people may be able to find them. Staff should consider using a first and middle name instead, and set public profiles to private.

Staff should not attempt to contact young people or their parents via social media, or any other means outside school, in order to develop any sort of personal relationship. They will not make any efforts to find young people or parents’ social media profiles.

Staff will ensure that they do not post any images online that identify children who are young people at Cluster activities without their consent.

Acceptable use of technology

Paid Staff will not use technology belonging to the Cluster to view material that is illegal, inappropriate or likely to be deemed offensive. This includes, but is not limited to, sending obscene emails, gambling and viewing pornography or other inappropriate content.

Paid Staff will not use personal mobile phones and laptops during face to face sessions in planned activities unless authorised to do so. If pictures/videos are taken on a photo camera/mobile phone then they must be deleted once the activity is completed and no longer needed.


In the course of their role, members of paid staff are often privy to sensitive and confidential information about people.
This information should never be:

  • Disclosed to anyone unless required by law or with consent from the relevant party or parties
  • Used to humiliate, embarrass or blackmail others
  • Used for a purpose other than what it was collected and intended for

This does not overrule staff’s duty to report child protection concerns to the appropriate channel where staff believe a child has been harmed or is at risk of harm, as detailed further in our child protection and safeguarding policy.

Honesty and integrity

Paid Staff should maintain high standards of honesty and integrity in their role. This includes when dealing with young people and vulnerable adults, handling money, claiming expenses and using school property and facilities.
Paid Staff will not accept bribes. Gifts that are worth more than £20 must be declared and recorded on the gifts and hospitality register.
Paid Staff will ensure that all information given to the Penlee Cluster is correct. This should include:

  • Background information
  • Qualifications
  • Professional experience

Dress code

Paid Staff will dress in an appropriate manner.
Outfits will not be overly revealing.
Clothes will not display any offensive or political slogans.

Conduct outside of work

Paid Staff will not act in a way that would bring Penlee Cluster, or church schools into disrepute. This covers conduct including but not limited to relevant criminal offences, such as violence or sexual misconduct, as well as negative comments about Penlee Cluster on social media.

Monitoring arrangements

This policy will be reviewed annually, but can be revised as needed by the Trustees of Penlee Cluster.
Our Trustees will ensure this code of conduct is implemented effectively, and will ensure appropriate action is taken in a timely manner to safeguard young people and vulnerable adults and deal with any concerns.

Links with other policies

This policy links with our policies on:

  • Staff disciplinary procedures, which will be used if staff breach this code of conduct. It also sets out examples of what we will deem as misconduct and gross misconduct
  • Health and Safety
  • Child protection and safeguarding
  • Whistleblowing
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