This is the public version of this policy. Details of our contracts with commissioning local authorities and some security arrangements are left out. Commissioning local authorities can ask us for the full version.

1. Purpose

This Code is our staff behaviour policy, as required by Keeping Children Safe in Education (KCSIE). It sets clear standards so that:

learners are safe and treated with dignity;
adults are protected from situations that could be misunderstood or lead to false allegations;
everyone knows what to do, and concerns are raised early.

Many of our learners have been harmed by adults, find trust hard and will test boundaries. Some of our staff already know learners and families through community work, sport or Dreams Are Real CIC. Both are reasons why clear boundaries matter more here, not less. Behaviour that falls short of this Code may be a low-level concern, an allegation or a disciplinary matter.

2. Scope

The Code applies to every adult who works with Care Cove AP learners: employed staff, agency staff from First Class Teachers, counsellors from My Solution Wellbeing, sessional and vocational tutors, volunteers, students on placement and members of the Social Work Management Committee (SWMC) when working with learners. It applies on site, off site, on transport, online and, where conduct could affect your suitability to work with children, outside work. Agency and partner staff sign the declaration before their first session.

3. Law and guidance

Keeping Children Safe in Education 2026, including Part Four.
Guidance for Safer Working Practice for those working with children and young people in education settings (Safer Recruitment Consortium).
Teachers' Standards, Part Two (personal and professional conduct), for teachers.
BACP Ethical Framework for the Counselling Professions and UKCP Code of Ethics, for counsellors; the NMC Code, for the Clinical Advisor.
Sexual Offences Act 2003 (abuse of a position of trust).
Equality Act 2010; UK GDPR and the Data Protection Act 2018.
Mobile phones in schools (DfE statutory guidance, 2026), which we follow in full.
Smoke-free (Private Vehicles) Regulations 2015.

4. Roles and responsibilities

Role	Responsibility
Director	Owns the Code, makes sure every adult has signed it before working with learners, keeps declarations on Connect and decides on serious breaches
Head of AP	Covers the Code at induction and in supervision, models it and deals with minor breaches
DSL	Advises on the safeguarding parts of the Code and on whether a breach is a safeguarding concern
SWMC	Ratifies the Code and receives concerns about the Director
First Class Teachers and My Solution Wellbeing	Make sure their staff have read and signed the Code before working with our learners
Every adult	Follows the Code, asks if unsure, self-reports anything that could be misunderstood and reports concerns about others

5. Our standards

Put learners' safety and wellbeing first, always.
Be a positive role model. Live the Respect Code: I respect myself; I respect everyone here; I respect this place.
Offer high care and high expectations together. Behaviour is communication.
Never correct or humiliate a learner in public. A first reminder is a private word.
Use your professional judgement. If something is not covered here, ask yourself whether a reasonable colleague would see your action as safe and in the learner's interest. If in doubt, ask, record and tell someone.

6. Professional boundaries

Your relationship with learners is professional, warm and boundaried. You hold a position of trust and must never use it for your own benefit.
Any sexual activity, sexual comment or romantic relationship with a learner is forbidden. Sexual activity with a person under 18 by someone in a position of trust is a criminal offence, whatever the young person says. Do not start a personal relationship with a former learner, or their family, that grew out of your work with them.
Do not have favourites, give learners special treatment or encourage dependency on you. Key mentor relationships are close by design, so discuss attachment in supervision.
Do not share personal problems or details of your private life that could burden a learner or be used against you.
Do not lend or borrow money, buy items for learners, or give or receive personal favours.
Never invite a learner to your home. Visit a learner's home only as a planned home visit under our home visit protocol.
If you already know a learner or their family, through family, neighbours, a sports club, community work or Dreams Are Real CIC, tell the Head of AP before you work with them. The relationship is recorded on Connect and a plan is agreed, which may mean you are not their key mentor.

7. One-to-one working and visibility

Nobody works unobserved with a learner.
One-to-one work (therapy, mentoring check-ins, 1:1 support in a learner's plan) is planned and recorded on the timetable or Connect. It takes place in a room with a glazed panel or with the door open, where other adults are nearby. Tell a colleague where you are.
Never lock a room with a learner inside. Regulation spaces are never lockable from either side. Never cover the glazed panel on a therapy room door.
Avoid out-of-sight places such as stairwells, empty rooms and unused floors.
One-to-one work off site, such as independent travel training or collecting a learner, needs a written risk assessment and the Head of AP's agreement. It takes place in public places, and you carry a phone.
Volunteers never work unsupervised and never work one-to-one with a learner.
Do not enter toilets while learners are using them, except in an emergency. If you do, tell another adult straight away. Any intimate care a learner needs because of a medical need or disability is set out in their plan.

8. Physical contact

Some physical contact is appropriate, for example first aid, guiding a learner away from danger, a brief side-on gesture of comfort for a distressed learner, celebrating with a high five, or demonstrating a technique in sport with the learner's agreement. Any contact must:

be for the learner's benefit, not yours;
be brief, in open view and suited to the learner's age, culture, history and wishes;
never involve intimate areas, kissing, front-on hugs or a learner sitting on your lap.

Ask before touching where you can. Some learners' plans say they should not be touched at all, because of trauma or sensory needs. Respect this.

Physical intervention (holding or restraint) is used only by Team Teach trained staff, as a last resort, and must be reasonable and proportionate, as the Positive Handling and Physical Intervention policy sets out. Every intervention is logged on Connect the same day and reviewed with the DSL within 24 hours. Parents and the school are told the same day, there is a debrief the same day, and the SWMC reviews patterns every term.

If a learner initiates contact, such as a hug, or any contact could be misunderstood, record it on Connect and tell the Head of AP.

9. Transporting learners

Learners are transported only under the Transport and Escorting policy. Drivers hold an Enhanced DBS check with barred list, escorts are deployed on risk assessment, and every journey is logged. No lone transport takes place without a written risk assessment. Never drive a learner in your own car or give a learner a lift; Care Cove uses licensed taxi operators.

10. Contact outside work and online

Never give learners or their families your personal phone number, personal email address or personal social media details.
Do not contact learners, or let them contact you, through personal phones, social media, messaging apps or gaming platforms. Do not follow, friend or accept requests from current learners, or former learners under 18.
Contact with learners and families is through Care Cove systems only: Care Cove devices and phones and Connect messaging (including the Family portal). Keep it to work matters and during reasonable hours.
If a learner or parent contacts you through a personal account, do not reply. Tell the Head of AP the same day and record it on Connect as a self-report.
If you meet a learner in the community, be polite and brief. Do not arrange to meet. Record anything that worries you.
If you work with children outside Care Cove, for example coaching at a sports club, declare it. Keep any contact with our learners in that setting professional and in line with that organisation's safeguarding policy.

11. Personal phones and devices

Do not use your personal phone in front of learners. We model the phone-free day that we ask of learners, in line with the DfE mobile phones guidance and our RESET curriculum. Keep your phone away and on silent during learner contact time, and use it only in staff areas during breaks. The same rules apply to smart watches.
In an emergency where no Care Cove phone is available, use your own phone to get help, then tell the Head of AP.
Never store learner information or images on a personal device. Learner data is kept only on Care Cove managed devices and Connect.

12. Photography and images

Take photographs or video of learners only on Care Cove devices, for a clear purpose such as learning evidence or celebrating achievement.
Check the learner's consent on Connect first. Some learners must never be photographed, for example where there are contact restrictions or risks; Connect flags this.
Never take images of a learner who is distressed, during a physical intervention, partly dressed, or in any way that could identify where they live or embarrass them.
Upload images to Care Cove systems and delete them from the device promptly. Never store them on personal devices or personal cloud accounts.
Publication, for example on our website or social media, needs separate written consent and the Director's approval. No image or post may mention our contracts with commissioning local authorities or use a local authority's name or logo without its written consent.

13. Gifts

You may accept a small token from a learner or family, such as a card or a homemade item, up to the value set in the Anti-Bribery and Anti-Corruption policy, and you record it in the gifts and hospitality register. Politely decline anything worth more. If refusing would cause real offence, accept it on behalf of Care Cove, record it and let the Director decide what happens to it. Never accept cash, vouchers or gift cards, and never ask for a gift.
Do not give personal gifts to individual learners. Rewards go through our agreed rewards system.
Gifts and hospitality from suppliers, schools or other organisations follow the Anti-Bribery and Anti-Corruption policy.

14. Confidentiality

Share information about learners and families only with those who need it, and only through Connect and other secure routes.
Never discuss learners in public places (including outdoor classrooms, trams and cafes), on social media or with friends and family.
Never promise a learner that you will keep a safeguarding concern secret.
Counsellors keep session content confidential but share risk and themes with the DSL.
Your duty of confidentiality continues after you leave Care Cove.
Pass any Freedom of Information request to the Director straight away, so it reaches the relevant commissioning local authority within 2 working days. Never answer it yourself. Pass any request for personal data to the Director too.
Report any data breach, such as a lost device or a misdirected message, to the Director immediately.

15. Dress and appearance

Dress practically and professionally for active work, PE, outdoor learning and workshop sessions. Avoid revealing clothing, and anything with offensive, political, drug, alcohol or gang-related images or slogans. Wear the right footwear and protective equipment for practical work. Wear your lanyard and ID where they can be seen at all times on site. Remove jewellery that could cause injury during PE or physical activity. We respect religious and cultural dress.

16. Language and behaviour

No swearing, bad language, or abusive or insulting language or behaviour towards or in front of learners. Learners may swear; staff do not.
No sarcasm, shouting, threats, humiliation or public correction.
No discriminatory language or jokes. Challenge prejudice, including racism, sexism, misogyny, homophobia and transphobia, every time.
Never display, access or share pornographic or offensive material on any device at work.
Do not talk about your own drug use, offending or sex life, and never glamorise gangs, violence, drugs or alcohol.
Be considerate and respectful to learners, families, colleagues, partners and local authority officers.

17. Smoking, vaping, alcohol and drugs

No smoking or vaping on site (inside or outside), at outdoor classrooms, on visits, in vehicles or anywhere learners can see you. This is in line with the smoking and vaping policies of commissioning local authorities. Smoking in a vehicle carrying anyone under 18 is also against the law.
Never buy, give, hold or share tobacco, vapes or alcohol for or with a learner.
Never come to work under the influence of alcohol or illegal drugs. Do not bring alcohol or energy drinks on site.
If you take prescribed or over-the-counter medicine that could affect your work, tell the Head of AP. Keep your own medicines secure and out of learners' reach.

18. Declaring relationships and conflicts of interest

Declare to the Director, in writing:

any existing relationship with a learner or their family;
a close personal relationship with a colleague where one of you manages the other or it could affect safeguarding decisions;
any relative or close friend applying to work with us;
any other work with children or young people;
any business interest connected with Care Cove or its suppliers.

Declarations are recorded in the conflicts register and managed under the Conflicts of Interest policy.

19. Reporting concerns about colleagues

You have a duty to report concerns about any adult's behaviour towards learners, whatever their role.

Share any low-level concern with the Director the same day, or with the SWMC Chair if it is about the Director.
Report any allegation that an adult may have harmed a child to the Director the same day, as the Managing Allegations Against Staff and Low-Level Concerns policy sets out.
Self-report anything you have done that could be misunderstood.
If you think a concern is not being dealt with, use the Whistleblowing policy.

Nobody will be treated badly for raising a concern honestly.

Set your personal accounts to private and check what learners and families could find about you.
Never post about learners, families, colleagues, schools or commissioning local authorities, or post images taken at work.
Do not post anything that could bring Care Cove into disrepute or make people doubt your suitability to work with children, including discriminatory, offensive or illegal content.
Do not post about our contracts with commissioning local authorities or use a local authority's name or logo without its written consent. Only staff authorised by the Director post on Care Cove accounts.
Never enter learner, family or staff personal information into a public AI tool. Use only tools the Director has approved.

21. Your suitability to work with children

Tell the Director straight away, and before your next shift (the SWMC Chair if this concerns the Director), if:

you are arrested, charged, cautioned or convicted of any offence, or are under police investigation, in the UK or abroad;
you are involved in any incident in which the police or children's social care become involved with children, including in your own household;
you become barred, prohibited or restricted by the DBS, the Teaching Regulation Agency or a professional regulator;
anything else happens that could affect your suitability to work with children, including a health matter that affects your ability to work safely.

If you also work in a Care Cove service providing registered childcare for younger children, the Childcare (Disqualification) Regulations 2018 may apply, and you must tell the Director about anything that could disqualify you. Failing to tell us is a disciplinary matter. Conduct outside work can be a transferable risk and may be referred to the LADO.

22. Breaches of this Code

Minor breaches are discussed with the Head of AP, recorded on Connect and may be recorded as a low-level concern.
Serious breaches are dealt with under our disciplinary procedure. Where the harm threshold may be met, the Managing Allegations Against Staff and Low-Level Concerns policy applies, including LADO referral and any referral to the DBS or Teaching Regulation Agency.
Agency and partner staff may be removed from work with Care Cove, and their organisation will be told.
Allegations of misconduct affecting a learner are reported to the commissioning local authority's contract manager, with a report of the investigation and action taken.

23. Monitoring and review

The Director owns this Code and the Social Work Management Committee ratifies it. Every adult signs the declaration at Appendix A before working with learners and again each year after the annual KCSIE update. The Head of AP covers the Code in supervision. The SWMC's termly audit of low-level concerns tests whether the Code is understood and followed. The Code is reviewed every year, or sooner after an incident, a change in law or statutory guidance, or a change to our contracts.

Appendix A: Staff declaration

I confirm that:

I have read and understood the Staff Code of Conduct, and I will follow it.
I have read the Safeguarding and Child Protection policy and KCSIE Part One (and Annex B if I work directly with learners).
I know who the Designated Safeguarding Lead and Deputy DSL are, and how to report a concern the same day.
I will not contact learners or their families through personal phones, email or social media, and I will not use my personal phone in front of learners.
I will never work unobserved with a learner, and I will never lock a room with a learner inside.
I will declare any existing relationship with a learner or family, and any conflict of interest.
I will tell the Director straight away about anything that could affect my suitability to work with children.
I understand that breaching this Code may lead to disciplinary action, a referral to the LADO, and referral to the DBS or a professional regulator.

Detail	Entry
Full name
Role
Employer (if agency or partner)
Signature
Date

The signed declaration is recorded on the staff member's Connect training record by the Data and Compliance Officer.

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.

Version	Date	Summary of changes	Approved by
1.0	1 October 2026	First issue	DSL; Head of AP

Role	Name	Date
Designated Safeguarding Lead	Pamela Shaw	1 October 2026
Head of Alternative Provision	Naphtali Nembhard	1 October 2026

Staff Code of Conduct