Code of Professional Conduct for Personal Relationships

Policy version control table.
Guidance Document Number:	23
Approved by:	Deputy Director of People and Culture
Date Approved:	April 2023
Next Review Date:	April 2026
Version Number:	4.0
Applicable Statutory, Legal or National Best Practice Requirements:	Changing the culture: tackling staff-to-student sexual misconduct – Universities UK Strategic guide for universities (2022) Office for Student’s statement of expectations (2021) Equality and Human Rights Commission’s Sexual harassment and harassment at work: technical guidance (2020) & Preventing sexual harassment at work: a guide for employers (2020) Equality Act (2010) Sexual Offences Act (2003)
Equality Impact Assessment Completion Date:	10 February 2023

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Contents Table
	Contents
1	Contents
2	Scope
3	Definitions
4	Responsibilities
	4.1 Line Managers
	4.2 Heads of School, Department or Service
	4.3 Staff
	4.4 People and Culture Directorate
	4.5 Student Services
5	General Principles
	5.1 Values
	5.2 Behaviours
6	Pre-existing Personal Relationship
7	Statement on Relationships between Staff and Students
8	Guidance for Students on Relationships and Disclosure
9	Statement on Relationships between Staff
10	Statement on Relationships between Staff and Close Personal or Business Associates
11	Reporting a Conflict of Interest
12	Appropriate Action and Alternative Arrangements
13	Implementation, Training & Monitoring
	Appendix A: Examples of when a personal relationship should be disclosed
	Appendix B: Glossary
	Appendix C: Guidance for Staff on Appropriate Relationship with Students

1 Introduction

The University is committed to providing a supportive, safe and inclusive working and learning environment, which ensures high standards of professional behaviour for all members of our University community and allows our staff and students to fulfil their personal potential. The University considers that staff and students are required to respect and maintain the boundaries of professional and personal life.

This Code of Professional Conduct outlines the University’s position on relationships between members of staff, between staff and close personal or business associates and between staff and students. The relationship between students and staff is central to the student experience and this guidance is intended to ensure that these relationships are professional, have boundaries and are founded on mutual trust and confidence.

This Code of Professional Conduct provides guidance when personal and professional relationships overlap, creating a potential, actual or perceived conflict of interest. Any form of harassment, unfair treatment or abuse arising from a personal or professional relationship will not be tolerated.

The purpose of this Code of Professional Conduct is to ensure that the correct procedure is followed so that staff are not open to allegations of misconduct, bias, abuse of authority, discrimination, conflict of interest or favouritism.

2 Scope

This Code of Professional Conduct covers personal relationships involving staff, students and others closely associated with the University, such as business associates.

This Code of Professional Conduct applies to all staff and students of the University of Bradford.

The term staff in this document includes:
• staff contractually employed by the University;
• workers, such as casual or part-time hourly paid staff;
• visitors (including researchers and lecturers);
• honorary appointed staff;
• examiners and invigilators;
• management/ IT consultants/agency staff;
• contractors and suppliers;
• all students engaged in teaching or other work activities;
• business associates or industry partners working closely with the University;
• other individuals who are involved with the University e.g. mentors, coaches, alumni.

The term student in this document includes:
• any current undergraduate, taught postgraduate or postgraduate research student, regardless of the mode, location, or duration of their studies;
• deferred students, interrupted students, visiting students, members of staff who are also students of the University;
• postgraduate research students who are also employed to provide teaching or assessment to other students.

3 Definitions

Personal Relationship – For the purposes of this Code of Professional Conduct a personal relationship is defined by a relationship between two people that can be categorised under one or more of the following headings:

1 Business, commercial or financial relationships including relationships where there is financial dependency;
2 Contractual relationships or partnerships;
3 Close family relationships (e.g. parents and grandparents, children and grandchildren, brothers and sisters, in laws, aunts and uncles, cousins);
4 Intimate relationships including marital, sexual, romantic or emotional relationships, however brief, regardless of gender, gender identity or sexual orientation.

Please refer to Appendix B: Glossary for definitions of other terms referenced in this Code of Professional Conduct.

4 Responsibilities

4.1 Line Managers

• Ensure that all disclosures of personal relationships are treated sensitively and confidentially;
• Report any personal relationships involving their direct reports to their Head of Department, School or Service, Dean or Director and the People Business Partner, where appropriate;
• Ensure that they are aware of this Code of Professional Conduct and it is disseminated to their team, when appropriate.

4.2 Heads of School, Department or Service

• Ensure that staff involved in relationships with one another are supported and do not suffer a detriment in relation to promotion, development or other professional opportunities as a result;
• Review and identify any impact a personal relationship may have within the University,
facilitate action or alternative arrangements to minimise any conflict of interest and the potential effect of the relationship on other staff and/or students;
• Raise any concerns with staff when personal relationships are reported involving their direct reports and other staff, students, or business associates to ensure that these may be dealt with in accordance with this Code of Professional Conduct;
• Ensure that all disclosures of personal relationships are treated sensitively and confidentially;
• Ensure that they are aware of this Code of Professional Conduct and it is disseminated to their team(s), when appropriate.

4.3 Staff

• Familiarise themselves with this Code of Professional Conduct.
• Disclose any relationship that they have which falls within the scope of this Code of Professional Conduct to their line manager or Head of School/Service. Should there be any doubt as to whether a relationship falls within the scope of this Code of Professional Conduct, advice should be sought from their line manager, Head of School or Service, or People and Culture Services;
• Conduct themselves at all times in ways that are consistent with University policies and procedures, including the University’s Safeguarding Policy, and acknowledge their professional and ethical responsibility to protect the interests of students;
• Follow reasonable management instruction in accordance with this Code of Professional Conduct that relates to a personal relationship with another staff member, student, or business associate.

4.4 People and Culture Directorate

• Provide advice and guidance to managers on the use of this Code of Professional Conduct;
• Monitor and maintain a secure record of personal relationships that exist in the University between staff, staff and students and staff and business associates;
• Treat all disclosures made to them as part of this Code of Professional Conduct confidentially.

4.5 Student Services

• Provide support, advice and guidance to students on the use of this Code of Professional Conduct;
• Signpost students to appropriate services, both internal and external, where additional support in relation to a personal relationship involving staff and student;
• Treat all disclosures made to them as part of this Code of Professional Conduct confidentially unless a safeguarding concern is identified, in which case the Safeguarding Policy will supersede this Code of Professional Conduct.

5 General Principles

5.1 Values

The University is committed to the implementation of this Code of Professional Conduct in accordance with the University values which are:
• Excellence – Excellence is at the heart of everything we do;
• Inclusion – Diversity is a source of strength and must be understood, valued, supported and leveraged;
• Innovation – We give invention light and celebrate creativity and innovation;
• Trust – Trust is the foundation of our relationships, underpinned by integrity in all we do.

5.2 Behaviours

The University of Bradford expects its staff to apply the highest standards of professionalism in their relationships with other colleagues, students, business associates and other members of the University community.

All members of staff are expected to carry out the work of the University in a professional manner which upholds the University’s values and standards of behaviour and delivers an outstanding student experience. This should be reflected in all interactions as a representative of the University and as a private individual.

Many staff are members of professional bodies and are also expected to uphold the values of their own profession and adhere to their appropriate codes of conduct.

All members of staff should seek to ensure that they do not engage in any activities which may bring the University or their own professional standing into disrepute and abide by the values and act in a respectful manner.

Where a personal or intimate relationship comes to an end, the University expects that all parties will continue to conduct themselves in a professional manner and avoid personal disputes which impact on the working environment or other staff and students. It may be appropriate for actions put in place by the University during the relationship, to continue for a period following the end of the relationship. In these circumstances, the parties involved will be consulted with and required to comply with reasonable actions.

6 Pre-existing Personal Relationships

The University recognises that a member of staff or student of the University may have a pre-existing personal relationship with another person who joins the University at a later date. In these cases, it is the University’s expectation that the relationship is declared, as set out in sections 7, 8, 9 and 10 of this guidance. In line with the University's Recruitment Policy, if a member of staff is involved in the recruitment process has a personal relationship with an applicant they must declare this and avoid any involvement in the recruitment and selection decision-making process. External and internal applicants for posts are asked to declare relevant personal relationships on application.

A personal relationship may already exist between two parties currently working, studying or closely associated with the University, for example spouses, relatives or close friends. Where any party is unsure if a relationship should now be disclosed following the revision of this Code of Professional Conduct, or where they were not aware of the existing guidance, they should approach the relevant contacts for confidential advice as set out in sections 7, 8, 9 and 10 of this guidance. Staff, students and business associates of the University can also contact the People Hub for confidential advice and guidance at any time.

It is recognised that not all personal relationships give rise to a conflict of interest and this Code of Professional Conduct does not apply in these cases. An actual or perceived conflict of interest will not necessarily arise from the mere fact of co- membership of a particular School, Planning Unit, Directorate, Faculty or Department or between peers within or across areas.

However, as set out in sections 7 and 8, all relationships between staff and students must be declared, whether new or pre-existing.

7 Statement on Relationships between Staff and Students

The staff–student relationship is one which should be characterised by the University’s values. Trust is considered the foundation of our relationships and is underpinned by integrity in all we do. The boundaries of the professional role of our staff must be fully recognised and respected by staff, who are in a position of power. The University considers that all staff are in a position of trust and power in relation to students.

The University expects all staff to conduct themselves at all times in ways that are consistent with University’s policies, procedures and values and to be accountable for their professional and ethical responsibility to protect the interests of students and accept the obligations and constraints inherent in that responsibility. Staff should be mindful of their obligation to promote the welfare of children, young people and adult at risk and adhere to the Safeguarding Policy and Procedures.

Members of staff are under a duty to act with integrity and not to place themselves in a position of actual or perceived conflict.
It is recognised that due to the structure and collegiate working environment, staff and students at the University will often come into contact both in their Faculty or Department and this can lead to the development of a personal relationship.

Such relationships raise issues concerning inequalities of power in a relationship, perceived favouritism, or the undermining of trust in academic processes. There is potential for sexual misconduct to occur due to the power and influence imbalance between staff and students. Consequently, intimate relationships between staff and students are strongly discouraged by the University.

In the event of a personal or intimate relationship developing with a student, the University requires that this is brought to the attention of the member of staff’s Line Manager, Head of Department or Dean/Director as soon as is reasonably possible in order that they can assess any potential conflict of interest and the risk of unintended consequences arising. The Manager/Head/Dean/Director may discuss the circumstances in confidence with the People and Culture Team. The Manager/Head/Dean/Director may also discuss the circumstances in confidence with the Student Success and Wellbeing team, to facilitate a supportive, impartial conversation with a student involved in a relationship with a member of staff.

Consideration will be given to putting in place measures to mitigate and reduce any current, potential or future conflict of interest. Any declaration of this kind will, so far as possible be treated in confidence, and every effort will be made to ensure that it does not disadvantage either party regarding their professional advancement or academic progress. Any offer of alternative or altered duties is dependent upon suitable work being available. The University will not be expected to create a post or unreasonably amend duties for the purpose of a staff member’s personal relationship with a student.

Disciplinary action may be taken against a member of staff who fails to declare a personal relationship with a student, or the likely commencement of such a relationship, as required by this Code of Professional Conduct.

A staff member who fails to adhere to action determined by the University in respect of a personal relationship will be deemed to have violated their ethical obligation to the student and to the University. In these circumstances, this will result in an investigation and may result in disciplinary action.

Staff and students should be aware that it is a criminal offence under the Sexual Offences Act 2003 to engage in sexual activity with a person under the age of 18, even where the person is of the legal age of consent, where the adult is in a position of trust, power or care in relation to the under 18 year old. The University considers that all staff are in a position of trust and power. This Code of Professional Conduct should also be read in conjunction with the University’s Safeguarding Policy and Dignity and Respect Policy.

If a personal or intimate relationship pre-exists between a member of staff and a candidate for admission as a student, the member of staff must make their Head of Department or Dean/Director aware of it at the outset of the admissions exercise, so that steps can be taken to avoid any conflict of interest arising. The matter will, as far as possible, be handled in confidence to ensure that there is no detriment to the candidate.

To avoid unnecessary misunderstanding and to maintain a professional relationship, staff are strongly discouraged from sharing personal information such as home addresses or telephone numbers to students.

Expression of a personal relationship in formal setting (e.g. in meetings) is not appropriate and staff in a personal relationship should ensure their own conduct remains professional in such settings. University premises and resources must be used solely for University business. Use of University premises or property for any sexual or intimate activity is strictly prohibited. Staff should refer to Appendix C: Guidance for Staff on Appropriate Relationships with Students, including unacceptable behaviour towards students.

8 Guidance for Students on Relationships and Disclosure

The University advises students not to enter any personal relationship with a member of University staff, as it may lead the staff member to compromise the integrity of their professional relationship.

If such a relationship develops, and the student is not sure if a member of staff has disclosed their relationship, they are encouraged to independently advise their Head of School/Department or Dean of the Faculty, in confidence. If a student does not feel comfortable speaking to their Head of School or Dean, they can also contact the University’s Safeguarding Team or Student Services teams for impartial support and advice.

Students who are, or who have been, involved in a romantic, sexual or intimate relationship with a member of staff and who do not consider their involvement to be truly consensual or if they consider that they have been adversely affected by a misuse of power, authority, or conflict of interest have the right of complaint under the University’s Dignity and Respect Policy.

Students can also seek support and advice from the University’s Safeguarding Team, Student Services teams or the University Police Constable if they do not consider their involvement in a relationship with a staff member to be truly consensual.

9 Statement on Relationships between Staff

It is recognised that staff will have a variety of mutually rewarding professional relationships which will not have a detrimental effect upon colleagues, integrity in their role or the running of the University.

Whilst most social relationships are beneficial in that they promote good working and academic relationships, it is recognised that there are occasions when personal relationships between staff members may lead to a conflict of interest.

Staff should declare an interest where a personal relationship exists in circumstances as detailed Appendix A or where their circumstances may reasonably be considered as a conflict of interest that impacts the integrity of the academic, administrative or institutional processes of the University or where there may be a perceived or actual imbalance of power, such that a colleague may be advantaged or disadvantaged by the influence or decision of the staff member with whom they are in a relationship.

Where a personal relationship occurs between staff, it is the responsibility of both individuals to consider whether there may be a conflict of interest or the potential for a conflict of interest to arise and then to deal appropriately with it and disclose the relationship, where appropriate.

Staff must not be the line manager of another member of staff with whom they have a personal relationship. It may be necessary to review the reporting structure if the relationship develops between a line manager and a member of their team. Staff should approach their Line Manager, Head of School/Department or Dean/Director for advice.

In addition to a supervisory/managerial relationship between members of staff, a conflict of interest can also arise in less formal situations where one member of staff has influence over academic, financial, progression or other opportunities of another member of staff with whom they are in a personal relationship.

Staff should take care that any personal relationships are entered into on a consensual basis and do not unfairly advantage or disadvantage any member of staff, potential member of staff, business associate or third party of the University (e.g. service providers).

Expression of a personal relationship in formal setting (e.g. in meetings) is not appropriate and staff in a personal relationship should ensure their own conduct remains professional in such settings. University premises and resources must be used solely for University business. Use of University premises or property for any sexual or intimate activity is strictly prohibited.

Where a personal relationship between staff leads to an actual or perceived conflict of interest or where there is a managerial or supervisory relationship between staff in a relationship, the following should be noted and followed:

• Staff are expected to inform their Line Manager or Head of Department/School as soon as possible to ensure that the potential effects can be considered. If the relationship is between a Head of Department/line manager and a member of staff whom they supervise, the relationship should be declared to a more senior manager, such as the Dean/Director. There will be no requirement to give specific, personal or intimate details of the relationship.
• The Head of Department/line manager must treat these matters in confidence and with sensitivity and respect at all times and will, in consultation with the staff, find ways in which actual, perceived or potential conflicts of interest might be avoided.
• A member of staff who is, or who has been, involved in a relationship with another member of staff and who does not consider their involvement to be consensual or who experience unwanted advances and other unwelcome behaviour have the right of complaint under the University’s Dignity and Respect Policy.

Failure to disclose a personal relationship between staff or failure to comply with action deemed appropriate to mitigate conflicts of interest may result in disciplinary action.

10 Statement on Relationships between Staff and Close Personal or Business Associates

This Code of Professional Conduct also applies to staff who begin a personal relationship with a client, customer, contractor or supplier or where a personal relationship exists and then becomes a business, commercial or financial relationship with the University.

If staff are involved in University business with organisations or individuals (including with contractors and service providers) with whom they have a personal or business relationship, they are required to disclose this to their line manager.

If a staff member’s role allows them authority over a client, customer, contractor or supplier (for example if they have authority to decide to whom to award contracts) the relationship must be declared to their Head of Department or Line Manager.

Where the University is made aware of such relationships, it will consider the appropriate action to take in order to protect the integrity and interests of all concerned and it would be expected that the staff involved would be removed from this element of University business.

Failure to disclose a conflict of interest in these circumstances may result in disciplinary action being taken.
Staff who are uncertain about whether they should disclose a personal relationship are invited to seek guidance, in confidence, from the People Business Partner/Advisor for their Department, School or Service.

11 Reporting a Conflict of Interest

Declarations of a conflict of interest by a member of staff should be made to a line manager or Head of School, Department or Service. Declarations of interest do not have to be in writing, however, a note of the declaration should be made by the manager who receives the declaration.

In the case of personal relationships between staff, and staff and business associates; People Business Partner/Advisor and Dean / Director will be informed.

In the case of personal relationships between staff and students the People Business Partner/Advisor and Dean / Director will be informed. Student services will also be informed of relationships declared between staff and students, in accordance with sections 6 and 7 of this Code of Professional Conduct to ensure that impartial support is available to students.

Heads of School, Department or Service are responsible for recording and reporting a conflict of interest disclosed to them, as set out above. Heads will arrange consultation with staff, students and business associates as required, to discuss and assess any conflict of interest and if any alternative arrangements are required to mitigate risks arising from a personal relationship, or if any further action is required in line with University policies and guidance.

Staff who are uncertain about what action to take should seek guidance, in confidence, from the People and Culture team.
Where the University is made aware of a relationship by another person or other means, this will be explored and a decision will be made if any further action is required in accordance with this and other appropriate University policies and procedures. Appropriate action will be taken to protect the integrity of all parties and procedures and deal with the matter as sensitively as possible.

12 Appropriate Action and Alternative Arrangements

When the University is made aware of a relationship covered by this Code of Professional Conduct, it will consider the appropriate action in a manner that protects the integrity of all parties. The parties involved will be consulted and expected to comply with all reasonable action. The University will try to ensure that these matters are dealt with in confidence and as sensitively as possible.

In implementing measures to manage any conflict of interest, the Head of School, Department or Service may, in consultation with the relevant Dean/Director, consider the following:

• if there is a supervisory, management, teaching or pastoral arrangement in place;
• the personal circumstances or any known vulnerability of a student at the time of the relationship (e.g. if the personal relationship existed prior to the staff/student relationship);
• any special family, kinship and elder relationships;
• the nature and frequency of the two individuals’ contact in study, research or employment;
• the potential for the staff member to influence the academic progress and outcomes or career progression of the student or colleague; and
• the extent of the power imbalance between the two individuals.

Appropriate action may include, but is not limited to:

• consulting with the member(s) of staff and student to identify any impact their relationship may have within the University;
• ensuring that appropriate action is taken to minimise the potential effect of the relationship on other staff and/or students;
• ending or modifying the professional connection between the parties to ensure there is no threat to the integrity of either party;
• Ensuring that the member of staff will not have an opportunity to directly, or indirectly, influence aspects of a student’s work which require judgement, e.g. academic assessment;
• ensuring that the staff member will not have an opportunity to directly, or indirectly, influence decisions affecting the student, including the provision or withholding of any of the following: facilities for research; the allocation of places on courses, bursaries or scholarships for research;
• facilitating the re-organisation of duties to minimise professional contact and ensure the member of staff is not tutoring, acting as a research supervisor, assessing or examining, providing pastoral care, or professionally responsible for administering activities in which the student is involved;
• ensuring that a declaration of interest is made, as appropriate, to the Chair of University committees, working groups, steering groups, School committees etc., in such a way as to protect the integrity of all parties and processes. Depending on the nature of the committee/group it may be inappropriate for the person to remain in membership. Alternatively, it may be appropriate for an individual to remain in membership and leave the room during certain items on the agenda or that they remain at the table but not participate in the discussion. It is the responsibility of the Chair to determine the appropriate response to the particular circumstances in consultation with the People and Culture team;
• In the case of a student whose studies or research are in a very specialised area, such that no alternative tutor or supervisor is available, the Head of Department, School or Service should consider whether it would be appropriate to engage a co-supervisor or external supervisor, to ensure that the member of staff does not have sole responsibility for supervision or decisions that affect the student;
• ensuring that a staff member does not have an involvement in taking or influencing decisions affecting the other staff member’s salary, terms and conditions of employment, role, workload, promotion, training and development, career development, staff appraisal or any formal University procedure relating to discipline, complaint or performance, and that this is carried out in such a way as to protect the integrity of all parties and processes. This may include the re-organisation of duties in this regard;
• where a member of staff is in a personal relationship with another staff member for whom they have line management or supervisory responsibility, an alternative line manager will be arranged;
• where a member of staff is in a personal relationship with another staff member for whom they have line management or supervisory responsibility or has influence over academic, financial, progression or other opportunities, where the actual or perceived conflict of interest cannot be resolved by other means and is adversely affecting work or other colleagues, it may be necessary to explore the possibility of moving one or both of the parties to other areas of work or location. This will only be done after all other reasonable alternatives have been explored;
• in line with the University's Recruitment Policy, if a member of staff involved in the recruitment process has a personal relationship with an applicant they must declare this and avoid any involvement in the recruitment and selection decision-making process. External and internal applicants for posts are asked to declare relevant personal relationships on application;
• if a member of staff who has a personal relationship with another member of staff and is involved in any committee, process or decision making relating to promotion, progression, development, University policies, or allocation of financial or other resources for the member of staff with whom they are in a relationship, they must declare this and avoid any involvement in the decision-making process;
• withdrawing from writing references and recommendations for the student or staff member with whom a staff member has a personal relationship.

Where there is failure to comply with this Code of Professional Conduct, disciplinary action may be taken.

Please note this list is not exhaustive. The circumstances of each individual case will be considered in determining the most appropriate action to be taken.

13 Implementation, Training & Monitoring

The Code of Professional Conduct is available on People and Culture ServiceNow.

Line Managers, Heads of School/Department and Deans/Directors are responsible for raising awareness of all new/updated guidance through their normal Faculty/Directorate communication channels.

This Code of Professional Conduct will be reviewed in accordance with the People and Culture Directorate’s policy review schedule.

Appendix A: Examples of when a personal relationship should be disclosed

The following represents circumstances where personal relationships between staff, staff and students, or staff and individuals seeking to or who have formed a business relationship with the University, must be declared. Please note this is not an exhaustive list.

• Management and supervision of staff or students;
• Recruitment and selection;
• Tendering and the awarding of work to external companies or bodies;
• Deployment of financial and other resources;
• Conference arrangements;
• All aspects of teaching, learning and assessment;
• Access to confidential information, including writing references and student records;
• Involvement in decisions affecting a student, including the provision or withholding of any of the following: facilities for research; the allocation of places on courses, bursaries or scholarships for research;
• Committee or working group membership;
• Contractual matters including employment, career opportunities, placements;
• Involvement in decisions affecting the other person’s salary, terms and conditions of employment, role, workload, promotion, progression, training and development, career development and staff appraisal or performance review;
• Policy matters including complaints, capability and discipline;
• Supervision of students;
• Pastoral or welfare support;
• Assignment of work and/or facilities to students;

Staff are required to declare a personal relationship with a student in all circumstances, regardless of job role or if they have any direct or indirect supervisory or pastoral responsibilities. This is to enable the University to assess whether any potential or actual conflict of interest exists or may arise.

Appendix B: Glossary

Abuse of Power – An abuse of power occurs when someone uses their position of power or authority in an unacceptable manner. Abuse of power can take various forms and may include, but is not limited to, grooming, manipulation, coercion, or putting pressure on others to engage in conduct they do not feel comfortable with. It may also include using a position of power to advantage or disadvantage someone else for reasons other than merit.

Conflict of Interest - A situation that has the potential to undermine the impartiality of a person because of the possibility of a clash between the person's self-interest and professional interest.

Consent to an intimate relationship – In order to have an intimate relationship consent must be given, but individuals must have the choice, freedom and capacity to give consent. It should not be assumed that this is always the case. The person seeking consent must ensure that it is freely given and is an informed decision. They must also be aware that it can be withdrawn at any time and past consent does not mean present consent.

Power Imbalance – A power imbalance is where one person can dominate decision-making or otherwise asserts power or influence in ways that disadvantages others or is not in the best interests of the other party (or parties). The balance of power may be affected by factors including, but not limited to, professional standing or position, gender, age, disability, sexual orientation, race or religion.

Sexual Harassment or Sexual Misconduct – All behaviour of a physically or emotionally intimate or sexual nature that, reasonably considered, is inappropriate and/or unacceptable whether it was intended or not. This includes unwanted behaviour of a sexual nature that:

1. Had the purpose, or may reasonably be considered to have the effect, of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for a student; or
2. Is an abuse of power over another person; or
3. Is more or less favourable treatment of someone because they have rejected or submitted to such behaviour – through any medium, including online.

Personal Relationship - A personal relationship is defined by a relationship between two people that can be categorised under one or more of the following headings:

a. Business, commercial or financial relationships including relationships where there is financial dependency;
b. Contractual relationships or partnerships;
c. Close family relationships (e.g. parents and grandparents, children and grandchildren, brothers and sisters, in laws, aunts and uncles, cousins);
d. Intimate relationships including marital, sexual, romantic or emotional relationships, however brief, regardless of gender, gender identity or sexual orientation.

Position of Power – The ability to influence and direct others based on the power associated with a formal position or role. For the avoidance of doubt, all staff are considered to be in a position of power and trust.

Appendix C: Guidance for Staff on Appropriate Relationships with Students

In order to maintain appropriate relationships with students, and to help reduce the risk of sexual misconduct, abuse of power or conflict of interest, it is recommended that staff adhere to the following when carrying out their role at the University:

• Carry out the duties of your role without any favour or advantage towards one student over another;
• Use your University email, Teams, phone and other associated software and communication methods to communicate with students where possible, Avoid contacting or responding to students through personal means (e.g. personal phone, messaging services or social media)
• Keep your communications professional. You should only need to contact students in relation to the business of the University and the student’s studies.
• Be mindful that any email to a student or about a student to another colleague, may be disclosable under relevant legislation (e.g. data protection, freedom of information, subject access requests)
• Avoid contacting students outside of working hours/days (e.g. evenings, weekends) or responding to contact from students outside of your normal working hours unless there is a genuine, exceptional or urgent circumstance such as out of hours contact from students working remotely in another time zone or on placement where they may work outside of University hours;
• Avoid wherever possible providing your personal information or contact details to students. University communication channels, such as email, Microsoft Teams, Skype for Business should be used in the first instance. Where this is unavoidable, staff should reiterate that the contact details are for a specific purpose e.g. arranging field trips, conferences.

Where a staff member has direct supervisory, teaching, assessment, mentoring, or pastoral/support role for a student, staff should also take the below guidance into account:

• Meetings with students should always take place on campus or University premises, unless unavoidable (e.g. field trips). Where this is not possible, other appropriate means should be explored e.g. meeting virtually on Teams, or in a public venue such as a library;
• When meeting students on campus, in a meeting room or a private office, care should be taken to ensure that the door remains open. In circumstances where this is not possible (for example, if a student wishes to discuss something confidential or sensitive) you should seek the student’s consent to close the door and re-open this as soon as is feasible. Under no circumstances should a door be locked when meeting with a student;
• Office facilities, particularly private offices, are to be used for University business only. These facilities should not be used to meet socially with students; in cases where staff may meet with students more socially (i.e. not for confidential discussion) then alternative meeting arrangements, such as the Atrium, Student Central should be considered;
• Consider referring students to the relevant University support service, if the support they require is not within the remit of your role;
• Do not seek any personal information from a student that is outside of standard University processes (e.g. medical information for LSPs or consideration for extensions).

All staff should be mindful of conducting themselves in an appropriate manner when interacting with students. To help minimise any suggestion of inappropriate behaviour, unprofessional conduct or sexual misconduct, staff should follow the below guidance on what is considered unacceptable behaviour towards students. Please note this list is not exhaustive.

• Physical touching which may be unwanted and could be construed as sexual in nature (e.g. touching a student’s shoulder, stroking their arm or hand, squeezing a student’s leg, initiating hugs) or any physical gesture that could cause distress or discomfort;
• Making comments or asking questions of a sexual, romantic or intimate nature (including via electronic communication, phone or social media) which may be viewed as offensive, indecent or cause discomfort;
• Paying particular or special attention to one specific student;
• University staff should generally decline all offers of gifts, other than those of a very small intrinsic value or on occasions where it is customary to exchange gifts, in line with the Hospitality Policy;
• Inviting an individual student to your home or private residence without others present, including while away from the University on placements, conferences or overseas trips;
• Staff should never ask a student to provide any personal services for them outside of their employment or engagement with the University.

Please note this guidance is not exhaustive and is intended to provide guidance to staff on appropriate behaviours towards students.