Code of conduct
Date approved: September 2025
Review date: September 2028
See below for the full policy, but please be aware this may include acronyms or technical jargon used internally within Raven. If you have any questions, please contact us.
1. Purpose of the policy
1.1. Everyone who works for, leads or represents Raven Housing Trust is held to the highest standards of conduct. This document sets standards appropriate for Raven and in line with the National Housing Federation’s Code of Conduct, ensuring alignment with Raven’s purpose, values and the delivery of its strategic objectives.
2. Scope of the policy
2.1. This Code of Conduct applies to all employees, volunteers, and Board and Committee members across Raven Housing Trust and its subsidiary entities. It establishes behavioural standards aligned with the National Housing Federation’s Code of Conduct and Raven’s organisational values. The document is structured into four thematic sections that reflect the mission of housing associations, with tailored guidance provided where specific requirements differ by role or group.
3. Code of conduct
Part one: Acting in the best interests of Raven Housing Trust and its customers
A. Meeting your responsibilities: You must fulfil your duties and obligations responsibly, acting at all times in good faith and in the best interests of the company and for the delivery of its strategic objectives.
Expected of all
A1: You must always try to fulfil the requirements of your role to the best of your ability. If any circumstances arise that limit your ability to meet your responsibilities, you must raise this through the appropriate channels.
A2: In carrying out your role, you must always seek to further the Company’s strategic objectives, reflecting the Company’s desired culture.
A3: You must not act in a way that discriminates against, or unjustifiably favours, particular individuals, groups or interests, including on the basis of any protected characteristics they may have.
A4: You must consider the impact of your actions on the safety and wellbeing of residents.
Expected of Board Members
A5: You must respect the principle of collective decision-making and corporate responsibility.
A6: You must ensure that you declare to the Company any relevant personal relationships, employment and other appointments you hold, and that these do not interfere with your ability to perform or conflict with your role as a board member.
Expected of Staff Members
A7: You must consult your manager before taking any other paid or voluntary work that may interfere with your existing job, or conflict with terms set out in your contract of employment
B. Representing Raven Housing Trust: In representing the Company at external events and in dealings with outside bodies or on social media, you are ambassador for the Company and must uphold and promote its values, objectives and policies.
Expected of all
B1: In representing the Company, you must act in accordance with its values, policies and goals.
B2: You must not conduct yourself in a manner that could reasonably be regarded as bringing the Company into disrepute.
B3: You must not make derogatory, false or otherwise damaging comments, in person or through any medium, about the Company or any person, service or organisation connected with it.
B4: You must not seek to officially represent the views or position of the Company without prior authority.
B5: You must adhere to the Company’s policies in the use of email, intranet and internet services including social media.
B6: When representing the Company through any medium, including social media, you must at all times act with professionalism.
B7: Where any personal social media accounts refer to your role with the Company, you must make it clear in what capacity you are communicating.
B8: If you intend to engage in an activity, including political or campaigning activity, which may reasonably be regarded to affect the Company, you must obtain prior consent. Such consent must not be unreasonably withheld unless your activity poses a material risk to the association.
Expected of Board Members
B9: Individuals with a conflict should not take part in discussions and decisions relating to that conflict and should be prepared to resign if the conflict is material or longstanding, and in the opinion of the board cannot be managed appropriately
Part two: Behaving with integrity
C. 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 to the Company and your personal interests, financial or otherwise.
Expected of all:
C1: You must formally declare to the company, at the earliest opportunity, any interests which may, or may be perceived to or may in the future, conflict with the duties of your role.
C2: You must declare any known relationship to a person applying for or performing a role within the company and must not be involved in their appointment, performance management or reward.
C3: You must declare any known relationship to a resident, potential resident or other customer of the company. You must not be involved in decisions relating to their relationship with the company or seek or accept preferential treatment for them.
C4: You must declare any known relationship to a person or organisation seeking appointment as a contractor or supplier to the association and must not be involved in their appointment, performance management or reward.
C5: Except where specifically permitted, as set out in the Company’s relevant policy, you must avoid using its contractors and suppliers for private purposes.
C6: You must not use, or attempt to use, your position to promote personal interests or those of any connected person, business or other organisation for personal gain.
Expected of Board Members
C7: Individuals with a conflict should not take part in discussions and decisions relating to that conflict and should be prepared to resign if the conflict is material or longstanding, and in the opinion of the board cannot be managed appropriately.
D. 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 an obligation to those individuals or organisations. You must not seek to accept preferential treatment in the provision of benefits such as housing accommodation or employment.
Expected of all
D1: You must not solicit or seek gifts or hospitality or other benefits.
D2: Any gifts or hospitality offered to or by you must be either declared on the Gifts and Hospitality Register or declined according to the Company’s policies. The only exceptions are gifts of token, value or modest hospitality given in connection with normal work meetings.
D3: If you are offered a bribe, hospitality or a gift, which is or may be in return for expected preferential treatment, you must decline and declare this immediately to the appropriate person.
D4: Anyone offering gifts should be asked to donate them to Raven’s charitable donations fund. How to deal with exceptions:
a) Only small personal gifts of less than c £50 in value (e.g., diaries, calendars, stationery) may be accepted.
b) Any other gifts received should be pooled and used for residents or other charitable benefit (e.g., directly or by sale or raffle). No personal benefit to individuals or groups of staff or members is permitted.
c) All gifts received must be recorded in the Gifts and Hospitality Register, kept by the Group Chief Executive, except for those outlined in section (D2) above.
d) Modest gifts to another individual or organisation are only to be made in exceptional circumstances, with the approval of an Executive Director.
E. Funds, resources ad personal benefits: You must not misuse the association’s funds or resources or seek preferential treatment for your own benefit.
Expected of All
E1: You must ensure that the Company’s funds and resources are used properly and efficiently.
E2: Your procurement decisions must be guided by the Company’s policies and fairness in decision-making and in line with relevant law.
E3: You must take all reasonable measures to protect the Company’s funds, resources, property and assets from fraud, theft, damage and misuse.
E4: If you claim reimbursement for any expenses, you must do so in line with the Company’s policies and procedures.
F. Confidentiality: You must process information in accordance with the law and the company’s policies and procedures.
Expected of All
F1: You must not disclose, without the required permission and authority, any personal data about tenants, customers, staff or colleagues. The Company’s policies and procedures give further guidance.
F2: You must not disclose, without authority, any confidential or sensitive business information. This duty continues to apply after you have left the Company or stepped down from your position.
F3: You must not, without authority, pass or distribute to the press or media or any other external recipient(s) any unpublished information or materials relating to the association, unless you are doing so in accordance with the Company’s Speaking Up (whistleblowing) policy and procedure.
F4: You must not prevent another person from gaining access to information to which they are entitled to by law.
G. Reporting concerns: You must report to the appropriate person within the company any reasonable and honest suspicions you may have about possible wrongdoing, in line with policies and procedures.
Expected of All
G1: If you have a concern about possible wrongdoing, you must immediately report it via the appropriate internal channel or external body. This includes becoming aware of potentially dishonest or fraudulent activity, and material breaches of this Code or relevant legislation including health and safety.
G2: If you believe that you are being required to act in a way which conflicts with this Code or legislation, you must immediately report it via the appropriate channel.
G3: You must not victimise or disadvantage any person who uses or intends to use the Company’s confidential reporting procedures to report actual or alleged wrongdoing.
Part three: Conducting yourself professionally and treating others well
H. Respect for others: You must treat others with respect and consideration at all times.
Expected of All
H1: You must treat everyone you meet in the performance of your role with equal respect, care and consideration.
H2: You must show respect for individuals’ chosen identities.
H3: You must promote, through your own behaviours, an organisational culture that is welcoming, accepting and accommodating to people of all backgrounds, cultures and personal and protected characteristics.
H4: You must not harass, bully or attempt to intimidate any person, or use threatening or aggressive behaviour or other discriminatory behaviours. You must seek to avoid microaggressions in your speech and behaviour.
H5: You must not display materials in your workplace or use language in the performance of your role which other people might reasonably find offensive.
H6: You must report through appropriate channels any instances of unfair or unequal treatment in the workplace and, where it is your role to do so, you must investigate any such reports thoroughly, with compassion and respecting confidentiality.
H7: You must be courteous to others during meetings, treat other attendees with respect, and respect the position of the meeting Chair. You must not use aggressive or threatening behaviour or act disruptively in any capacity.
H8: You must be punctual to all meetings that you are a member of or send apologies in advance.
I. Relationships between board members, staff and involved residents: Board and Committee members, staff, and involved residents must maintain a constructive, professional relationship based on a sound understanding of their respective roles.
Expected of All
I1: You must seek and value views from residents and other customers when making decisions that will affect them.
I2: You must not allow any personal relationship with a resident or other customer to influence how you discharge your role and responsibilities.
I3: You must not give personal gifts or loans of money to, or receive personal loans or gifts of money from, residents or other customers.
I4: You must handle residents’ and other customers’ money only where necessary and ensure that a receipt is completed for every transaction. In any event, you must operate in accordance with the association’s financial policies, procedures and controls to ensure appropriate handling of all funds.
I5: You must not invite or influence a resident or other customer unless they are a person who you are closely connected to, to make a will or trust under which you are named as executor, trustee or beneficiary.
J. Relationship with customers, residents and other service users: You must maintain high standards of professionalism, fairness and courtesy in all your dealings with customers, residents and other service users.
Expected of All
J1: You must not ask or encourage the commitment of wrongdoing, including any breach of this Code.
Expected of Board Members
J2: Your relationships with staff and involved tenants must be constructive and professional.
J3: 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.
Expected of Board Members and involved Residents
J4: Where it is necessary to raise issues of staff, board or contractor performance, these must be raised constructively and through the appropriate channels.
J5: You must not undermine or appear to undermine the authority of a senior officer in their dealings with a more junior member of staff.
J6: You must behave in a professional manner, always maintaining independence and integrity. This will include avoiding inappropriate personal familiarity with members of staff.
J7: Unless you have specific and, where practicable, written delegated authority to do so, you must not individually give instruction or direction to any member of staff or contractor.
Expected of Staff Members
J8: You must behave in a professional manner, always maintaining independence and integrity. This will include avoiding, in a professional setting, inappropriate personal familiarity with board members and involved residents.
J9: You must not use informal channels to lobby or influence board members or involved residents on matters of the Company’s business.
J10: You must not knowingly mislead the Board or any of the Company’s committees or panels. In presenting information, you must set out the facts and relevant issues and risks truthfully.
K. 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.
Expected of All
K1: You must play an active part in the Company’s supervision and performance appraisal processes as applying to you.
K2: You must offer open and constructive feedback to others and invite feedback about your own performance.
K3: You must make your personal training, and development needs relevant to your role known to the association.
K4: Unless there are exceptional reasons, you must attend learning and development events as required.
Expected of Board Members
K5: You must keep your knowledge up to date in those areas in which you are a specialist, as well as keeping abreast of any matters relating to your association and the wider housing sector.
Part four: Protecting yourself, other people and the environment
L. Health, safety and security: Your conduct, actions and decision making must promote the health, safety or security of yourself or others.
Expected of All
L1: You must not knowingly put your own or others’ health, safety, security or wellbeing unnecessarily at risk.
L2: If you have any concerns about the health, safety, security or wellbeing of yourself, another individual or a group of individuals connected with the association, you must report this immediately through the appropriate channels.
M. Protecting the environment: Within your role at the association, you must strive to avoid or reduce possible negative environmental impacts.
Expected of All
M1: 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.
Expected of Board Members
M2: You should consider the long-term environmental impact of your decisions.
4. Applicability
4.1. This Code applies to all employees and volunteers, and all Board and Committee members of Group companies. Where there are specific requirements for each group these are separated by subheadings.
5. Related policies and references for more information
5.1. Information about related policies or procedures, guidelines, forms, etc. Give complete references and ensure that documents cited are readily available. If needed, provide additional background discussion here.
- Probity policy
- Fraud and bribery protection, detection and response policy
- Data protection policy
- Speaking up (whistleblowing) policy
- Social media policy
- Procurement policy
- Fraud register
- Gifts and hospitality register
6. Implementation procedures
6.1. All Staff are required to sign up to the Code of Conduct on appointment as it will be integrated into induction programmes for new staff and board members.
6.2. The approved Code will be distributed to all staff, whenever it is reviewed.
6.3. Monthly internal emails are sent to all staff as a reminder, highlighting key behavioural expectations.
6.4. The Code will be uploaded to the accessible SharePoint site for all policies (and a summary version published on Raven’s website.
6.5. Reporting mechanisms are in place for reporting breaches and incidents, such as the Speaking Up (Whistleblowing) Policy, Fraud Register, and the Gifts and Hospitality Register).
7. Policy impact
7.1. The Code reinforces Raven’s commitment to integrity, professionalism, and respect, which directly enhances customer trust and employee accountability. It sets clear behavioural expectations for all staff, volunteers, and board members, promoting a consistent and respectful working environment.
7.2. The Code supports inclusive practices by applying uniformly across all roles and levels, with no exemptions unless explicitly stated.
7.3. The Code mitigates legal risk by requiring compliance with laws and internal policies on data protection, procurement, fraud prevention, and whistleblowing, thereby reducing exposure to regulatory breaches and litigation. It strengthens governance by mandating declarations of conflicts of interest, prohibiting bribery and misuse of resources, and enforcing confidentiality, which collectively safeguard the organisation’s integrity and legal standing.
7.4. The Code promotes efficient use of resources by mandating responsible procurement and safeguarding against fraud, misuse, and preferential treatment. It enhances organisational effectiveness by fostering integrity and accountability, thereby improving trust and reducing reputational and operational risks.
7.5. The Code requires all individuals to consider the environmental impact of their actions and seek positive outcomes where possible, reinforcing sustainability as a shared responsibility. Board members are specifically encouraged to factor long-term environmental consequences into their decisions, promoting strategic alignment with sustainability goals.