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Staff Code of Conduct Policy


This code of conduct has been drawn up to assist members of CTS to maintain an entirely proper and professional relationship with all learners and should be read in conjunction with the CTS Safeguarding and Prevent Policy.

All members of CTS Training who collaborate with learners especially those who are deemed as vulnerable are required to demonstrate high standards in their exercise of authority, their management of risk, in the proper use of resources, and in the active protection of vulnerable individuals from discrimination and avoidable harm. Staff are required to be vigilant of their own conduct and that of others, so that their relationships with learners and vulnerable individuals remain, and are seen to remain, entirely proper and professional. 

It is recognised that staff is susceptible to the potential for malicious or unfound allegations being made against them arising from the normal and proper associations with vulnerable individuals. This document is designed to be useful both for staff in avoiding situations that might lead to allegations being made against them and to reassure other parties (e.g., parents, partners, ESFA and Ofsted, etc) that a strategy exists to safeguard learners and vulnerable individuals.


Members of CTS staff are in a position of trust, and as such, have a duty of care to learners and Vulnerable Individuals for whom they are responsible. These principles are intended to guide members of staff on how to deal with learners especially those who are deemed as vulnerable:

•    Try to ascertain the wishes and feelings of the learner and be always respectful of these.
•    Provide understanding and empathy, whilst at the same time being non-judgmental and remaining impartial.
•    Give consideration for the learner’s personal characteristics (e.g., age, gender, etc), and the circumstances that define them as a vulnerable individual (if applicable).
•    always putting the best interests of the learner first.

Guidelines for Staff Conduct and Behaviour

 Physical Contact

•    As a general principle, staff should not have unnecessary physical contact with learners. There may be rare occasions when a learner needs comfort or reassurance, which may result in minor physical contact. Any such comforting gestures must always be acceptable to and consented to by the learner concerned. If an individual refuses, or the member of staff is any doubt whatsoever, no physical contact should be made. However, be aware that any physical contact could be misconstrued by the learner, a parent, a carer, or an observer. Although innocent and well-intentioned, repeated formal or informal gestures (such as putting a hand on the shoulder or arm), could lead to fundamental questions being raised.

•    The physical punishment of any learner (vulnerable or otherwise) is unlawful, as is any form of physical response to misbehavior unless it is by way of restraint (see below). It is particularly important that employees understand this, both to protect their own interests and that of the organisation.

•    Any instance of inappropriate or non-consenting physical contact is to be reported to the Designated Safeguarding Lead/Deputy Lead or Representative for further investigation.

The Practice of Physical Restraint

Restraint can be defined as the reasonable application of the minimum necessary force to overpower someone with the intention of preventing them from harming themselves or others, or from causing considerable damage to property.

There may be occasions where it is necessary for a member of staff to physically restrain a learner to prevent him/her from inflicting injury to themselves, to the member of staff, or to others. In such cases, only the minimum force necessary must be used and any action must be limited purely to restrain – no other actions are permissible.

Restraint should only be used exceptionally, when unavoidable and be commensurate to the situation and the individual concerned. To this end, restraint should only be considered a response to an immediate and unexpected scenario, or as a last resort having tried alternative methods to diffuse a situation.

Restraint should not be used as a form of punishment or to enforce compliance with instructions. It should not be attempted where the member of staff is put at undue risk and should only be performed in accordance with any training that has been provided.


Where the member of staff has taken action to restrain a learner/vulnerable individual, he/she must report the matter to their line manager. Statements should be acquired from the parties involved (including any witnesses). The incident must be referred to the DSR for further investigation. 

Sexual Contact and Harassment

Members of staff are not to engage in (or seek to engage in) a relationship of a sexual nature with any learner, vulnerable or otherwise, irrespective of them being over the age of consent and/or having given direct or implied consent to the member of staff. 


Sexual activity extends to touching (or attempted touching), the showing of sexually explicit material, sexual discussion, connotation, or innuendo.


Where a relevant topic (eg. sexual health and wellbeing) are being discussed in class, the member of staff should be mindful of keeping everything in context and within the parameters of the lesson plan. However, the raising of a legitimate issue or question by a learner is best addressed in the appropriate manner, rather than being ignored.

Due to the magnitude of any incident of a sexual nature towards a learner, it will always be treated as gross misconduct and disciplinary action taken as appropriate.

To protect your own interests and that of the organisation, any instance of a learner making advances of a sexual nature towards you, must be reported to your line manager immediately. 

Meetings with Learners 

Staff should be aware of the potential risks which may arise from interviewing learners especially those who are deemed as vulnerable in private. However, it is equally recognised that there will be occasions when private and confidential interviews cannot be avoided. Where this is the case, interviews should be conducted in open-plan areas where other members of staff are present, whilst still affording a degree of privacy for the individual. 

Where it is decided to use a room to conduct the interview, the room should have windows and/or doors/walls with vision panels to adjacent rooms or areas. Another member of staff should also be made aware of who is being interviewed, where, and, if known, for how long. After the stated duration has elapsed, the other member of staff should check the interview room. 


Where present, privacy blinds should not be drawn, and the use of “engaged” or “do not disturb” signs should not be used.

Where an important meeting with a vulnerable individual is scheduled, consideration may want to be given to the presence of their parent/guardian or carer. If deemed necessary to ask a vulnerable individual to stay for any length of time after the end of normal hours, sufficient warning must be given to their parent/guardian or carer.

Meetings with learners should not take place off CTS premises unless the venue is at that of a partner organisation (e.g., The Probation Service). Meetings between staff and a learner at either person’s home are prohibited unless accompanied by another member of staff or external partner.


Requests by a learner for a lift to a personal appointment should not be agreed to without prior consent from a line manager and where possible they should be organised and undertaken by their parent/guardian or carer.

Where the appointment is linked to the learner's training or is for external support e.g., CAMHS, housing appointment then it might be appropriate for a staff member to give the learner a lift, but this must be agreed with management and adequate supervisory ratios need to be adhered to. 

The use of a member of staff’s car should only be considered where:

The destination is not adequately served by public transport.

  • A second member of staff is in attendance.

  • The member of staff has the appropriate insurance for business use.

  • All instances where a member of staff proposes to use their car to transport a learner must be approved by their line manager.

First Aid

If a learner complains of injury or sickness requiring immediate attention, they should be referred to one of the nominated CTS First Aiders. For any non-urgent medical matters, the learner should be advised to make an appointment to see their own doctor. In the event of an urgent medical emergency, an ambulance should be summoned.

When the administering of First Aid is required, the First Aider should (wherever possible) ensure that another adult is present to prevent any necessary physical contact from being misconstrued. This is particularly important if the injury is in a personal area of the body or where clothing is required to be removed to access the injury.

Wherever possible, one of the members of staff present should always be of the same gender as the learner being treated.

The learner’s parent/guardian or carer may also need to be informed of any first-aid treatment given.


Male staff should not, as a rule, enter female toilets, nor should female staff enter male toilets. The exception to this rule is in the event of an extreme situation such as fire, or where there is severe injury or threat to life. 


All First Aiders must have an enhanced DBS check and be informed of any pre-existing health conditions as they may be the cause of a learner’s vulnerability. 

Provision of Advice and Guidance


Staff will often be approached by a learner for advice. Similarly, a member of staff may feel the need to ask about their well-being if they are distressed or behaving in a way not considered normal to the individual. In such cases, staff must judge whether it is appropriate for them to offer counseling and advice, or whether to refer the individual to another member of staff with the appropriate expertise and/or experience. If anything is disclosed by the learner that gives cause for a Safeguarding concern, then staff should inform the Safeguarding Representative/ Safeguarding Deputy or Lead, and the Safeguarding Cause for Concern form should be completed. Under these circumstances, staff should use their discretion to ensure that any questions or probing of details cannot be construed as an unjustified intrusion.

Staff should be conscious of any advice given, the effect of that advice being acted upon by the learner, and any changes that may result that could exacerbate a situation or their circumstances.

Social Contact

Social contact with learners (other than that which occurs on CTS premises or activities organised by CTS) should be avoided as far as reasonably possible.

It is recognised that there may be occasions when unintentional social contact occurs (eg. at venues open to the public, in shops, parks, etc.) In such circumstances, staff should be always mindful of the upkeep of their professional relationship with learners.

Staff may have cause to contact learners via electronic communication (ie. email, internet, mobile phones, social media, etc.). Any legitimate use of these methods should be limited to professional reasons, using CTS resources only. When using these forms of communication, staff should be careful that their use of language/terminology could be misconstrued.

Members of staff should not under any circumstance add a learner to their contact lists on internet social networking sites such as Facebook, Twitter, etc., or engage in online chat. This requirement extends to disclosure to a learner of other personal contact details such as email addresses, mobile phone numbers, etc.

Any attempt by a learner of unsolicited electronic contact (or other means), must be reported to the member of staff’s line manager.

General Relationships with Young Learners and Vulnerable Adults

Staff should ensure that their relationships with vulnerable individuals are commensurate to the age, gender, and circumstances of that person. 

Care should be taken to ensure that their conduct does not give rise to comment or speculation. 


The use of abusive, insensitive, derogatory, or sarcastic comments is not acceptable on any level.


If a member of staff feels at any time that their relationship with a learner is not being upheld in a purely professional manner, it is their responsibility to discuss the situation with their line manager.


If a member of staff feels uncomfortable around a learner or is in any doubt as to how best to approach or manage a situation, they should always discuss their concerns with their line manager or any other member of the management team or Safeguarding Representative.

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