Ember Learning Ltd
1. Purpose
This Code of Conduct sets out the ethical principles and professional standards that apply to everyone associated with Ember Learning Ltd. It establishes the values and behaviours that underpin how we operate as an organisation — with commissioning authorities, with students, with teachers, and with each other.
This Code is distinct from the Teacher Behaviour Policy (ET-TBP-001), which sets out operational conduct standards specific to the delivery of sessions. This Code operates at a higher level: it articulates the values that inform those operational standards and that apply across the whole organisation.
2. Scope
This Code applies to:
- All Company directors
- All self-employed teachers and associates
- Any other person acting on behalf of Ember Learning Ltd in any capacity
3. Core Values
Ember Learning is founded on the belief that every young person deserves a fair chance to learn and to be treated with dignity. Our work with vulnerable students in alternative provision demands that we hold ourselves to high standards in everything we do. Our core values are:
The welfare of children comes first. Every decision we make — operational, commercial, and interpersonal — is made with the welfare of the students we serve as the primary consideration. No other interest overrides it.
Integrity. We are honest, transparent, and consistent in our conduct. We do not misrepresent our qualifications, our services, or our compliance status.
Respect. We treat every student, commissioner, teacher, and colleague with dignity and without discrimination. We do not tolerate conduct — internal or external — that falls below this standard.
Accountability. We take responsibility for our actions and decisions. We report concerns. We do not ignore wrongdoing. We do not cover up mistakes.
Professionalism. We represent Ember Learning with consistency and care. Our conduct — in sessions, in communications, and in our professional relationships — reflects the trust placed in us by commissioning authorities and the families of the students we serve.
4. Conflicts of Interest
All persons associated with Ember Learning must avoid situations in which their personal interests conflict, or could reasonably be perceived to conflict, with the interests of the Company or of the students we serve. Where a potential conflict arises, it must be disclosed to a Company Director promptly. The Company Director will determine whether and how the conflict can be managed.
Examples of conflicts that must be disclosed include: a teacher privately teaching a student they have met through Ember Learning; a director having a financial interest in a supplier engaged by the Company; a director being personally connected to a commissioning officer with whom the Company is negotiating.
5. Gifts and Hospitality
No person associated with Ember Learning should offer, solicit, or accept gifts, hospitality, or other benefits that could reasonably be seen to influence their professional judgement or the decisions of others. Modest, occasional, and proportionate hospitality (for example, a working lunch in the context of a business relationship) is acceptable. Any offer of hospitality or a gift that goes beyond this should be declared to a Company Director.
Teachers must not accept gifts from students, parents, or carers. This is an absolute rule regardless of the value of the gift.
6. Use of Position
No person should use their position with Ember Learning to obtain personal advantage, to access information beyond what is necessary for their role, or to exercise inappropriate influence over students, commissioners, or colleagues.
All persons must use the authority and information their role gives them solely in the legitimate interests of the Company and the students it serves.
7. Confidentiality
All persons associated with Ember Learning have a duty to protect the confidentiality of information about students, commissioning authorities, commercial arrangements, and the Company’s internal operations. This duty applies during and after any engagement with the Company.
Confidentiality does not override the duty to report. Where confidential information relates to a safeguarding concern, it must be shared with the DSL in accordance with the Child Protection and Safeguarding Policy. Safeguarding always takes precedence.
8. Social Media and Public Conduct
All persons associated with Ember Learning must ensure that their public conduct — including on social media — does not bring the Company into disrepute, undermine trust in the Company’s suitability to work with children, or identify or expose students in any way.
No person should post content that: identifies a student or commissioner; discloses details of sessions; makes claims about the Company that are false or misleading; or engages in discriminatory, offensive, or inappropriate conduct. This applies to personal accounts as well as any account associated with the Company.
9. Safeguarding as a Non-Negotiable
Every person associated with Ember Learning has an unconditional duty to safeguard the welfare of the students we work with. This duty cannot be waived, overridden by commercial considerations, or subordinated to any other interest. Compliance with the Child Protection and Safeguarding Policy (ET-CPSP-001) is mandatory for everyone this Code covers.
Any person who has a safeguarding concern — however minor or uncertain — must report it. Failure to report is a serious breach of this Code and may result in termination of engagement and referral to statutory authorities.
10. Low-Level Concerns
Low-level concerns are those where a member of staff or associate has behaved in a way that is inconsistent with this Code of Conduct, but where the behaviour does not meet the threshold for referral to the LADO or the police. Identifying and addressing low-level concerns early is essential to maintaining professional boundaries and preventing escalation.
Examples of low-level concerns include, but are not limited to:
- Being over-friendly with students in a way that blurs professional boundaries
- Using language that is inappropriate for a professional educational context
- Showing favouritism or singling out individual students
- Making inappropriate posts on social media relating to students, commissioners, or the Company
- Any behaviour that, while not immediately reportable, gives rise to unease about a person’s conduct with children
A pattern of low-level concerns — even where each individual incident seems minor — can meet the threshold for LADO referral or disciplinary action. Low-level concerns must therefore be recorded and not dismissed.
Procedure for responding to a low-level concern:
- The concern must be reported to the DSL (Jack Bradley) promptly — verbally and then in writing
- The DSL will collect relevant information, speak with the person concerned and any witnesses where appropriate, and keep a written record in line with UK GDPR and the Data Protection Act 2018
- The DSL will advise what action should be taken; final decisions rest with a Company Director
- The DSL may consult the LADO to determine whether a concern is low-level or requires formal referral
- A record of all low-level concerns will be maintained by the DSL and reviewed periodically to identify any patterns
Where a low-level concern involves the DSL, it must be reported directly to a Company Director.
11. Raising Concerns
Any person who believes that this Code has been breached — by themselves or by any other person — should raise the concern promptly with a Company Director. Where the concern involves a Company Director, it should be raised with another director or with an external body as set out in the Whistleblowing Policy (ET-WBP-001).
No person will be disadvantaged for raising a genuine concern in good faith.
12. Breaches of This Code
Breaches of this Code will be taken seriously and addressed in a manner proportionate to their severity. For teachers, a breach may result in formal discussion, written warning, suspension, or termination of their agreement, and may be referred to the DBS or statutory authorities where appropriate. For directors, a breach will be addressed through the Company’s internal governance process.
13. Declaration
All teachers are required to confirm that they have read, understood, and agree to comply with this Code of Conduct as part of their onboarding. Directors confirm their commitment to this Code on an ongoing basis through their role in the Company.
14. Review
This Code will be reviewed annually by the Company Directors and following any significant incident or change in the nature of the Company’s operations.
Adopted 1 July 2026 · Version 1.0 · Policy owner: Kate Bradley, Director & Education Lead · Next review due 1 July 2027 (or earlier if a trigger event occurs). The full policy document is available on request — contact hello@embertutors.co.uk.