Guided by ELSC mission and values, we are committed to working with honesty, respect, and a strong sense of responsibility and accountability including respect for human rights, non-discrimination, anti-racism, social justice, and compliance with the applicable laws in the countries where we operate. This Code of Conduct serves as an organisational roadmap for ethical behaviour, procedures and accountability, helping us build trust and produce positive impact through safe and inclusive practices with everyone we work, support and collaborate with.

1. SCOPE

This Code of Conduct sets out the principles and guidelines that govern ethical behaviour, integrity, and professional conduct within our organisation. It applies to all components of the ELSC “our target group”, including:

• ELSC activities and operations across Britain and EU.  
• Clients, volunteers, stakeholders, partner organisations or third parties.  
• The activities of the ELSC abroad.  

The Code of Conduct covers the following types of unacceptable behaviour:

• Interpersonal misconduct: sexual harassment, intimidation and violence; aggression, discrimination and bullying;  
• Financial misconduct: fraud; improper use/misuse of funds; theft; blackmail, tax evasion and asset management/investments contrary to organisational objectives;  
• Abuses of power: corruption; conflicts of interest and nepotism; manipulation or misuse/leaking of information.  

2. OBJECTIVES

The objective of this code is to guarantee that:

• Our target group knows we must prevent and address any injustice caused by our staff or those working with or for ELSC. 
• Our target group is aware of the available channels to report these types of incidents;  
• We ensure that this Code of Conduct applies to activities related to contractual obligations between the ELSC and third parties.  
• All ELSC staff, representatives, and clients must uphold the dignity and safety of our target group and avoid actions that could lead to violence, fraud, corruption, or abuse of power.  

3. DEFINITIONS

Violence against someone in our target group

All forms of violence, physical or mental abuse or neglect, emotional and physical mistreatment, sexual abuse and exploitation, harassment and other forms of exploitation or violence in which a member of the ELSC is a victim of.

Violence

Includes any actions or inactions by individuals, groups, institutions, or organizations that may lead to actual or potential harm, or a significant risk of harm, to the well-being, dignity, survival, and development of another person.

Harm

Any adverse effect on a person’s physical, psychological or emotional well-being or on their financial situation. Such harm can be the result of intentional or unintentional abuse or exploitation.

Fraud

Any intentional act or negligence in which deception is used to obtain an advantage to which one is not entitled to and/or which affects the rights of others. Fraud is a broad concept and has many manifestations, such as deliberately providing false information or withholding information for (personal) (financial) gain or to disadvantage someone else.

Abuse of power, bribery and corruption

Misuse of authority for personal gain or attempting such misuse. This includes offering, promising, giving, accepting or requesting money, gifts or other private benefits in exchange for an illegal activity, abuse of power or other improper behaviour while carrying out the relevant activities.

Corruption

Corruption can also entail nepotism or favouritism arising from a conflict of interest. Fraud and corruption are not necessarily aimed at the financial or material gain of one person. These practices may also involve intangible benefits such as status or information and can benefit an individual as well as a group.

Protection of our target group

Our responsibilities and the preventive, reactive and referral measures that we take to protect our target group to prevent them from experiencing any form of injustice or disadvantage because of their involvement in activities that are carried out within the context of contractual obligations with the ELSC. Care must be taken to ensure that such activities are carried out safely.

If concerns are raised about the well-being of individuals in our target group, or if someone from this group has experienced violence, appropriate measures will be taken to address the issue. These incidents will be analysed to facilitate continuous learning within the organisation.

4. GENERAL PRINCIPLES

All ELSC staff

• must act in accordance with ethical standards and laws application in the jurisdiction that they operate in;  
• must commit and contribute to creating an environment in which our target group feels respected, supported, safe and protected;  
• may never commit acts that result in violence against anyone in our target group or that expose anyone in our target group to the risk of violence;  
• must be aware of and endorse the provisions of this code;  
• must sign this Code of Conduct to indicate their compliance with the Code of Conduct;  
• must report concerns about the safety of our target group and any code violations in accordance with the applicable procedures.  

All ELSC staff understands that:

• discrimination, harassment, and any form of unethical behaviour are strictly prohibited.   
• confidentiality and privacy must be maintained in all professional engagements.   
• conflicts of interest must be disclosed and managed appropriately.   
• the Code of Conduct is not to be invoked and/or misused to harm members of the target group or the organisation for personal gain 

5. CODE OF CONDUCT

Interpersonal misconduct

The ELSC is committed to creating a safe environment for our target group. All staff have a duty to uphold the principles of this code. They commit to safeguarding an environment focused on preventing violence against our target group.  

The ELSC considers sexual exploitation and abuse by staff as serious offences and therefore just cause for dismissal.  

As a staff member or person who works with, for or on behalf of the ELSC, I will therefore do the following:  

• I will comply with the Code of Conduct and be open and honest with people in our target group.  
• I will respect the rights, integrity and dignity of people in our target group and keep their interests in mind during my interactions with them, regardless of sex, gender, gender identity, sexual orientation, age, nationality, ethnic origin, colour, race, language, political or religious affiliation, disability, physical or mental health, class, prior contact with the criminal justice system, migration status, marital status, family situation, and socio-economic or cultural background.  
• I will respect the privacy and personal data of those in our target group.   
• When taking pictures of or with staff: ensure that the use of such images does not expose the person to the risk of being identified or located, if this could compromise the person’s safety;  
• I will report concerns, suspicions, incidents and accusations involving actual or potential violence against someone in our target group and act in accordance with the applicable ELSC policies, as set forth in Section 9 of the Code of Conduct.  
• I will give my full and confidential cooperation to any investigation carried out by the ELSC or by any organisation contracted by the ELSC into suspicions or allegations of violence against people in our target group.  
• I will immediately report to the HR manager all allegations, convictions and other consequences of a criminal offence that have occurred between me and people from our target group, and that are related to the exploitation or abuse of someone from our target group.  

I will not:

• deliberately act in a way that is humiliating, degrading or offensive towards people in our target group or commit any other act that is tantamount to emotional abuse;  
• treat certain people in our target group differently, discriminate against them or favour them over others;  
• start a relationship with people from our target group or engage in practices or adopt behaviour that can be considered or interpreted as offensive or abusive in any way (for staff, see Staff Relationships in the Staff HR Policies);  
• tolerate illegal, dangerous or abusive behaviour from people in our target group, and/or participate in such behaviour myself;  
• use computers, mobile phones, digital cameras or similar media devices to exploit, harass or intimidate people in our target group

Financial misconduct

We will not make illegal payments, perform or ask for illegal favours or take any other actions that could expose the ELSC to risks of financial loss, dependency, blackmail, extortion, legal sanctions or damage to our reputation. We have a zero-tolerance code regarding all forms of fraud and corruption.

As a staff member or person who works with, for or on behalf of the ELSC, I will therefore:

• handle ELSC assets and resources appropriately;  
• ignore or reject all allusions to engaging in fraud or corruption;  
• record the details of the situation as soon as possible in the event of a request to commit fraud or corruption, an attempt to commit fraud or corruption, or a case of actual fraud or corruption;  
• immediately report all such requests, attempts and cases of actual fraud or corruption to my manager or to an internal or external confidential advisor;  
• inform the Finance Manager or an internal confidential advisor as soon as possible and share relevant details with this person, in the event of suspected fraud or corruption or of suspicious actions and situations;  
• report imminent or potential conflicts of interest to my line manager at the earliest possible stage;  
• cooperate fully during investigations by sharing all relevant information with the appropriate people and agencies and by participating in interviews.  

Issues to consider in the case of potential financial misconduct

The following examples (note: this list is not exhaustive) may be cause for suspicion and may help in identifying fraud and corruption:

• Irregularities in financial records, such as: Descriptions of transactions that are vague, inconsistent, incomplete or incorrect, incomplete or unusual details about the identity of the other party in a transaction;  
• Abnormally large payments without an explanatory note; Unusual payment patterns or structures;   
• The use of different accounts, which can allow incorrect payments to be concealed; Erroneous, unusually large or an unusually high number of invoices and expense claims.  
• Requests to make payments to a party that you have not contracted, in a country where you are not carrying out activities, in cash or in a non-traceable currency (i.e. untraceable funds).  
• In case of an audit: misrepresentation or refusal to cooperate.  

Abuse of power

As a staff member or person who works with, for or on behalf of the ELSC, I will:

• Formulate agreements with clients, volunteers, donors, and third parties as clearly as possible to avoid misunderstandings or false expectations.  
• Consult with my line manager before making any exceptions to established rules or procedures.  

I will not:

• Give preferential treatment to personal or professional contacts, such as prioritising requests without consultation or providing biased assessments.  
• Review or handle requests from individuals I know personally on a biased basis; instead, I will consult my line manager to assess whether to reassign such cases to a colleague. 
• Disseminate information—internally or externally—that is confidential or could reasonably be considered confidential, except in cases involving violations of this Code of Conduct or national law.  
• Use the ELSC’s staff details, or information regarding clients, donors, partner organisations, or others in the ELSC network, for personal or private purposes.  

Conflict of interest

A conflict of interest exists where the ‘impartial and objective exercise of the functions of an actor or other person’ involved in a case, project, financial activity, contractual obligations or other work from the ELSC, as well as compliance with applicable laws or regulations, ‘is compromised for reasons involving family, emotional life, political or national affinity, economic interest or any other direct or indirect personal interest. A conflict of interest can arise even if the person does not actually benefit from the situation, as it is sufficient that circumstances indirectly compromise the exercise of their functions in an objective and impartial manner. However, such circumstances must have a certain identifiable and individual link with or impact on concrete aspects of the conduct, behaviour or relationships of the person.

As part of my responsibility to maintain impartiality and integrity, I will:

• Prevent conflicts of interest when engaging consultants or selecting new staff.  
• Exercise caution if individuals I have a close personal relationship with are under consideration for roles or assignments for which I hold responsibility.  
• Ensure that any selection or appointment is made strictly based on objective, merit-based criteria.  
• Recuse myself from any selection process where a potential conflict of interest exists, and request that an impartial colleague handle the matter. 

6. INTEGRITY IN PROFESSIONAL CONDUCT

In the event of a violation of this Code of Conduct, an investigation will be launched based on the relevant procedures and contractual agreements, or the file will be handed over to the official authorities for the purpose of launching a legal investigation under the laws of the country where the individuals concerned work.  
   
Violations may be punished with penalties, including disciplinary actions that can result in dismissal, the severance of all ties including contractual agreements and, if necessary, legal proceedings or other appropriate measures.   
   
Allegations and suspicions that have been reported in good faith will never have negative consequences for the whistle-blower, regardless of the outcome of the investigation and even if the report turns out to be unfounded. If it becomes clear that the report was intentionally made to tarnish the image of innocent parties, this will be considered a serious offence for which sanctions may be imposed.  

7. SAFE AND RESPECTFUL WORK ENVIRONMENT

The ELSC is committed to a safe working environment. As such, the ELSC promotes a culture of inclusivity and mutual respect. As a staff member or person who works with, for or on behalf of the ELSC, I will therefore:

• Not discriminate, harass or bully anyone from our target group;   
• Report any allegations of discrimination, bullying, harassment, abuse of power and conflict of interest following this Code of Conduct and the ELSC’s policies.  
• Commit to ensuring workplace safety, both physical and psychological  

8. CONFIDENTIALITY, DATA PROTECTION AND INTELLECTUAL PROPERTY

• Staff, consultants and collaborators must safeguard the ELSC intellectual property and proprietary information – including but not limited to reports, publications, training materials, research outputs, data sets, software, the CSM, visual assets and advocacy tools – bearing in mind that it remains the property of the ELSC, unless otherwise specified in written agreements.  
• Staff, consultants and collaborators may not reproduce, share, modify, or use such materials for personal, commercial or external purposes without prior written authorization. Likewise, all personnel are expected to respect third-party intellectual property rights and proprietary information.  

9. REPORTING VIOLATIONS AND ENFORCEMENT

Clients and Stakeholders are encouraged to report violations of this Code without fear of retaliation. Staff are required to file a complaint through the relevant internal means, including the Grievance and Conflict Resolution Policy.

Reports will be investigated fairly, and appropriate disciplinary action will be taken when necessary. The Investigation of allegations will be thoroughly investigated following the Complaints handling procedure.

10. COMPLIANCE AND IMPLEMENTATION

• All ELSC staff must acknowledge and adhere to this Code.  
• Training and awareness programs will be conducted to reinforce ethical practices.  
• This Code will be reviewed periodically to ensure its effectiveness and relevance.