DRAFT Breach of Code of Conduct Policy 2025

BREACH OF CODE OF CONDUCT POLICY 2025 This policy was approved by the Committee of Management on Wednesday 20th August 2025 It should be reviewed again no later than 31st July 2028.

The policy has been assessed through the organisational impact assessment process.

We can, if requested, produce this document in different formats such as larger print or audioformat. We can also translate the document into various languages, as appropriate.

SCOTTISH HOUSING REGULATOR STANDARDS

STANDARD 1 The governing body leads and directs the RSL to achieve good outcomes for its tenants and other service users.

STANDARD 2 The RSL is open about and accountable for what it does. It understands and takes account of the needs and priorities of Its tenants, service users and stakeholders. Its primary focus Is the sustainable achievement of these priorities.

STANDARD 3 The RSL manages its resources to ensure its financial well-being, while maintaining rents at a level that tenants can afford to pay.

STANDARD 4 The Governing body bases its decisions on good quality information Information and advice and identifies and mitigates risks to the organisation’s purpose.

STANDARD 5 The RSL conducts its affairs with honesty and integrity.

STANDARD 6 The Governing body and senior officers have the skills and Knowledge they need to be effective.

WEST GRANTON HOUSING CO-OPERATIVE LIMITED 26 Granton Mill Crescent Edinburgh EH4 4UT Tel: 0131 551 5035 Email: mail@westgrantonhc.co.uk West Granton Housing Co-operative Limited is a fully mutual housing co-operative registered as a social landlord with the Scottish Housing Regulator (HAC 225); and is a registered society under the Co-operative and Community Benefit Societies Act 2014 (2357 RS).

Contents 1.0 1.2 2.0

INTRODUCTION.........................................................................................................4 Allegation of breach..................................................................................................4 WHAT CONSTITUTES A BREACH?...........................................................................4

2.1

Breaches can include (but are not limited to):............................................................4

2.2

Examples of a serious breach of the Code of Conduct..............................................4

2.3

Minor performance related issues, actions or conduct...............................................5

2.4

Anonymous complaints.............................................................................................5

3.0

RESPONSIBILITY FOR OVERSEEING ALLEGED BREACHES.................................5

3.1

The Scheme of Delegation.......................................................................................5

3.2

Concerns..................................................................................................................6

3.3

Consultation.............................................................................................................6

3.4

Impartiality................................................................................................................6

3.5

External Advice.........................................................................................................6

3.6

Alleged breaches during a Committee meeting or internal event...............................6

3.7

Post event discussion...............................................................................................6

4.0

INITIAL REVIEW TO DETERMINE WHATACTION IS REQUIRED..............................7

4.1

Purpose of the Review..............................................................................................7

4.2

Exercise of judgement..............................................................................................7

4.3

Recording and reporting the outcome of a review......................................................7

5.0

INVESTIGATION REQUIRED......................................................................................7

5.1

Notifiable Event........................................................................................................7

5.2

Investigation.............................................................................................................8

5.3

Impartial alternative.................................................................................................8

5.4

The CEO..................................................................................................................8

5.5

Allegations of a potential breach...............................................................................8

5.6

Written or verbal complaints......................................................................................8

5.7

Notification – individual Committee member..............................................................8

5.8

Notification – to the Committee of Management........................................................9

5.9

Contributors to an investigation.................................................................................9

6.0

THE INVESTIGATION.................................................................................................9

6.1

Investigator(s)...........................................................................................................9

6.2

Written brief............................................................................................................10

6.3

Interviews...............................................................................................................10

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7.0

CONSIDERING THE OUTCOME OF THE INVESTIGATION.....................................10

7.1

Report review........................................................................................................10

7.2

Report consideration by Committee........................................................................10

7.3

Notification of investigative findings.........................................................................10

8.0

ACTION TO DEAL WITH A BREACH........................................................................11

8.1

Serious breach.......................................................................................................11

8.2

Record retention....................................................................................................11

8.3

Notification to SHR..................................................................................................11

Appendix 1............................................................................................................................12 Template Description of Oversight Role.............................................................................12 Appendix 2............................................................................................................................13 Template Letter to Inform Governing Body Member of an Investigation..............................13 Appendix 3............................................................................................................................14 Brief for the Conduct of an Independent Investigation.........................................................14

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1.0

INTRODUCTION

This protocol sets out the procedure for West Granton Housing Co-operative (WGHC) to deal with alleged potential breaches of the code of conduct for Governing Body Members (Committee of Management).

It is based on the SFHA model protocol and guidance provided by both the Scottish Federation of Housing Associations (SFHA) and the Scottish Housing Regulator (SHR).

1.2

Allegation of breach

An allegation that the Code has been breached is a potentially serious matter and this protocol is not expected to be referred to regularly.

A failure to participate effectively in WGHC’s governance may constitute a breach of the code, but the first step should be to engage with the Committee of Management to address the issue where an individual member’s contribution to WGHC’s governance is not meeting expectations (e.g. attendance and/or lack of preparation for meetings; participation in training).

A conversation will be arranged between the member concerned and the Chair where any challenges being encountered by the member can be identified and understood and where support can be offered. Only if performance does not improve will action in relation to a potential breach of/failure to uphold the code of conduct be considered appropriate.

2.0

WHAT CONSTITUTES A BREACH?

A breach of the Code is a potentially serious matter and some complaints and / or concerns may relate to relatively minor matters whilst others may involve more significant issues. It is important to distinguish between issues that might initially be relatively minor and/or described as / performance related from unacceptable conduct, non-exhaustive examples below: (such as bullying, offensive or discriminatory behaviour, seeking personal gain/benefit.)

2.1

Breaches can include (but are not limited to):  Conduct by a WGHC Committee member during a meeting e.g. being obstructive, offensive, disregarding the Chair or failing to observe Standing Orders,  Complaints that the behaviour of a WGHC Committee member has failed to meet the requirements of the code of conduct, is contrary to WGHC’s values, rules or policies, threatens the reputation of WGHC, risks bringing the organisation into disrepute or undermines WGHC and / or its people,  Inappropriate behaviour towards colleagues, staff, tenants, customers or partners.

2.2

Examples of a serious breach of the Code of Conduct

WGHC will regard the following actions as a serious breach of the Code of Conduct. This list is not exhaustive.  Failure to act in our best interests and / or acting in a way that undermines or conflicts with the purposes for which we operate.

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 Support for, or participation in, any initiative, activity or campaign which directly or indirectly undermines or prejudices our interests or those of our service users, or our contractual obligations.  Accepting a bribe or inducement from a third party designed to influence the decisions we make.  Consistent or serious failure to observe the terms of the code of conduct.  Serious inappropriate behaviour towards a colleague, member of staff, tenant, customer, partner or other stakeholder 2.3

Minor performance related issues, actions or conduct

Minor issues, actions or conduct e.g. at an internal meeting or event are unlikely to constitute a breach of the code of conduct. Complaints and / or concerns relating to relatively minor matters, isolated incidents and / or those that can be described as 'performance related’ matters and depending on the details of individual circumstances, are unlikely to constitute a breach of the code and do not constitute notifiable event to the SHR. Such matters will be dealt with by the Chair. The Chair will meet with the Committee member to discuss any challenges being encountered and to identify any additional support or training required. Further similar incidents of potential breach of / failure to uphold the code of conduct will be subject to investigation and action as set out in this protocol.

2.4

Anonymous complaints

In the event that anonymous information is received or made known, an initial review will be undertaken to establish whether there is the potential for any substance to the concern and if so, an investigation will be undertaken.

3.0

RESPONSIBILITY FOR OVERSEEING ALLEGED BREACHES

3.1

The Scheme of Delegation

The scheme of delegation identifies who has primary responsibility for overseeing the management of alleged breaches of the code of conduct.

3.2

Delegated Authority to Oversee Potential Breaches

Any two from the following (must include at least one Committee of Management member

Committee of Management

Chair, Vice-Chair, Committee member

Senior Staff

CEO, COO, or other grade 8 or 7 position

Concerns

Concerns about a Committee member’s conduct should be communicated to the Chair who is then responsible for deciding how to proceed and leading the agreed process unless the allegation relates to him / her.

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In that event, the Vice Chair should take on the responsibilities that the protocol allocates to the Chair. In the event that the allegation relates to both the Chair and the Vice Chair other members of the Committee of Management will be asked to take on the responsibilities.

Support may also be provided by WGHC’s solicitor or an external adviser. In such circumstances, the solicitor / adviser may, by agreement, fulfil duties otherwise undertaken by the Chair, but will always be accountable to the Chair and the Committee of Management.

The references to “Chair” throughout this protocol, as they relate to the investigation and management of complaints, should be interpreted as applying to whoever is charged with conducting / overseeing the specific responsibilities.

3.3

Consultation

On becoming aware of a concern or complaint, the Chair will consult with the Vice-Chair (or other members of the Committee of Management) to decide on the appropriate way forward and, where further action is deemed appropriate, instruct, progress and conclude investigations in accordance with this protocol.

3.4

Impartiality

No one who is directly involved in a matter that gives rise to a concern that there may have been a breach of the code of conduct should be involved in reviewing, conducting, managing or investigation of the matter. Persons involved should be impartial.

3.5

External Advice

The Chair may seek advice from our solicitors and / or obtain other external support that may be needed in exercising any or all of the responsibilities associated with this protocol.

3.6

Alleged breaches during a Committee meeting or internal event

Alleged breaches that occur during the course of a meeting or other internal event (and which have not happened before) will, unless the Chair believes it to be serious (e.g. offensive language or behaviour), be dealt with by the Chair of the meeting, either during the meeting / event and / or within 24 hours of the meeting.

In these circumstances, the Chair may ask the member to leave the meeting or a vote may be taken to exclude the member from the rest of the meeting.

3.7

Post event discussion

After the meeting, the Chair will discuss such behaviour with the member and may require the member to apologise or take such other action as may be appropriate. Where the Chair regards such behaviour as being serious, it should be actioned in accordance with the process set out in this Protocol as will repeated incidents of a similar nature.

4.0

INITIAL REVIEW TO DETERMINE WHATACTION IS REQUIRED

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4.1

Purpose of the Review

When a complaint is received or a concern is raised, a review will be conducted by those members of the Committee of Management appointed in accordance with 2.3 of this protocol, with support from the CEO (acting as Secretary) if required.

This is a brief overview of the concern / complaint to establish the most appropriate course of action and is not an investigation into the issue. The purpose of the review is to: a) clarify the complaint/concern/allegation b) determine whether there is sufficient information to take the matter forward c) if there is, agree what action set out in this protocol is appropriate 4.2

Exercise of judgement

Just because the code of conduct may be referred to does not automatically require action.

If the review concludes that there is nothing to support the matter being pursued (e.g. because the concerns are vague and / or because the anonymity of the allegations(s) make further investigation impossible or because the complaint is obviously malicious) no further action should be taken.

The Chair (and Vice-Chair) will exercise their judgement in determining which of the course of action set out in this protocol is most appropriate and will record the reasons for their decision.

4.3

Recording and reporting the outcome of a review

Those making the decision will record an explanation for the reason for their conclusion. In some cases, the outcome of the review may be reported to the Committee of Management e.g. if an anonymous complaint is received, which cannot be investigated because of a lack of information.

5.0

INVESTIGATION REQUIRED

Where an initial review concludes that the matter potentially constitutes a significant / major breach of the code, and / or where there are repeated breaches, an investigation will be required.

The reason(s) for the selected course of action will be recorded as part of the case file, which will be maintained throughout the investigation as an audit trail of how the complaint was addressed.

5.1

Notifiable Event

Serious complaints, allegations, investigations, or disciplinary action about the conduct a Committee member are notifiable events, in accordance with the terms of the Scottish Housing Regulator’s (SHR) Statutory Guidance.

The Chair is responsible for ensuring that the necessary notifications are made to the Scottish Housing Regulator, and that the SHR’s requirements as set out in the relevant guidance in terms of reporting the outcome of the investigation are met.

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5.2

Investigation

The Chair in cconsultation with the Vice Chair will instruct an independent investigator to conduct the investigation.

In the event that the Chair and/or the Vice Chair /other office-bearers are the subject of a complaint, other Committee of Management members will instruct the independent investigator.

5.3

Impartial alternative

If the Chair and / or Vice Chair are likely to be involved in an investigation (e.g. as a witness), it will be necessary to consider who should be involved in overseeing the investigation as no one who may be party to the investigation can be responsible for overseeing it.

5.4

The CEO

The CEO can support the implementation of the protocol, including providing advice to the Chair (unless involved in the issue, in which case the role should be assigned to another senior member of staff or to the organisation’s solicitor or other specialist adviser).

5.5

Allegations of a potential breach

Allegations of a potential breach should normally be made to the Chair or, where the complaint relates to the Chair, to the Vice-Chair. Where a complaint is made to the CEO, the matter should immediately be notified to the Chair or to the Vice-Chair, if the Chair is involved.

5.6

Written or verbal complaints

Alleged breaches may be the subject of written complaints or allegations; they may also be witnessed by someone. However the alleged breach is identified, the Chair and Secretary will ensure that there is a written statement of the complaint or allegation that is used as the basis for the investigation.

If no written complaint is made, the statement of the matter will be prepared by someone unconnected to the event / situation (e.g. a verbal complaint made by a Committee of Management member will be recorded by someone who was not present when the issue arose – e.g. a member of staff).

5.7

Notification – individual Committee member

The Committee of Management member(s) who is / are the subject of the complaint / allegation that is to be investigated will be notified in writing of the alleged breach within seven working days, either of occurring or of receipt of the complaint.

A Committee of Management member who is subject to an investigation will be required to take leave of absence until the matter is resolved in accordance with 34.8 of our Rules which set out the provisions to secure this.

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The letter will inform the Committee of Management member of the nature of the potential breach (referring to the specific part(s) of the code that the complaint relates to), the arrangements for the investigation and will advise that leave of absence will be in place for the duration of the investigation.

Committee of Management members are required to co-operate with such investigations1. The Committee of Management will record any decision to grant any leave of absence.

5.8

Notification – to the Committee of Management

An alleged breach of the code of conduct which is being investigated will be notified to the Committee of Management, normally by the Chair or Secretary, within seven working days, either of occurring or of receipt of the complaint.

The notice (which is confidential) will not describe the detail of the complaint and will set out the proposed arrangements for investigation, including who will conduct the investigation (if known) and which members of the Committee are responsible for overseeing it.

5.9

Contributors to an investigation

Existing and former members of the Committee of Management may be identified as being able to contribute relevant information to an investigation: the code of conduct requires current and former Committee members to contribute to an investigation and a failure to co-operate (by either the subject of a complaint or a Committee member asked to contribute) would, itself, constitute a breach of the code.

Former members of the Committee who left more than a year before the complaint is made will not, usually, be approached.

6.0

THE INVESTIGATION

The conduct of an investigation will remain confidential, as far as possible, in order to protect those involved (witnesses, complainant(s)) and the Committee of Management member(s) who are the subject of the complaint.

All investigations will be objective and impartial. The aim will be to conclude the iinvestigation within six weeks where possible.

6.1

Investigator(s)

The investigator(s) will be supported by the CEO (or other senior member of staff if the CEO is involved in the complaint). The Chair and Vice-Chair, with any support they feel necessary, will brief the agreed investigator and then consider the investigator’s recommendations at the end of the investigation, before reporting to the Committee of Management.

6.2

Written brief

All investigations will be the subject of a written brief which sets out the Committee’s requirements and statement of the alleged breach 1

Code of Conduct F7

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(scope, timescale, reporting requirements, access to information etc.).

The brief will refer to any action previously taken that is or may be relevant.

6.3

Interviews

All investigations will include at least one interview with the Committee of Management member(s) who is / are the subject of the allegation, who will be invited to provide any relevant information.

The interview(s) may be conducted face to face or remotely (by telephone or video call).

Committee of Management members may be accompanied during an interview by a friend (at their request), as a companion to provide support only, and not to represent.

Another Committee of Management member cannot fulfil this role, and WGHC will not meet any costs (other than reasonable expenses as provided for in the relevant policy) in respect of a companion’s attendance.

7.0

CONSIDERING THE OUTCOME OF THE INVESTIGATION

7.1

Report review

Before the report is presented to the Committee of Management the report will be reviewed by those overseeing the investigation to ensure that the brief has been met and that the report is adequate to support the Committee’s consideration and decision making.

The Committee of Management member(s) whose conduct is being investigated will not be party to any of the discussions relating to the investigation.

7.2

Report consideration by Committee

The report will be considered at a meeting of the Committee of Management, which may be called specifically for this purpose. It is the responsibility of the Committee of Management to consider the report and findings from the investigation and to determine:  Whether there has been a breach  If there has, how serious a breach it is  What action should be taken and the outcomes to be achieved 7.3

Notification of investigative findings

The Committee of Management will report the findings of the investigation and any proposed action(s) to the member concerned, in writing, within seven days of the meeting at which the report of the investigation was considered.

The Investigator will provide written conclusions that can be incorporated into this communication. The Chair will ensure that, in addition to the formal notification, there is personal contact with the Committee member(s) whose conduct has been investigated to explain the Committee of Management’s conclusion, any action to be taken and the outcome to be achieved. If the complaint is not upheld, this will be made clear and the Committee member(s) will be formally welcomed back from leave of absence at their first meeting.

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8.0

ACTION TO DEAL WITH A BREACH

If, following investigation, a breach of the code is confirmed, the Committee of Management will determine what action will be taken in response. This action will reflect the seriousness of the circumstances and the impact and will be informed by the facts, findings and recommendations of the investigation.

The Committee of Management will exercise good governance and act in the best interests of WGHC in their decision making and will ensure that actions are proportionate. Actions may include:  A discussion with the member concerned (which may be confirmed in a subsequent letter)  Advice and assistance on how their conduct can be improved  The offer of training or other form of support  Request to make an apology - the Committee of Management will be provided with confirmation that an apology, in appropriate terms, has been made  Requirement to undertake training - the governing body will be informed of completion of the required training  a formal censure (e.g.in the form of a letter setting out the conclusions, expressing concern and specifying that there must be improvement / no repetition etc)  Request to resign from an office bearing role (if relevant)  Request to resign from the Committee of Management  A vote to remove the Member from the Committee of Management 8.1

Serious breach

Where, it is concluded that a serious breach has occurred, the Committee of Management may require the member to stand down from their position in accordance with the rules.

If the Committee of Management proposes to remove a member from the Committee, following investigation, the member will have the right to address the full Committee of Management before their decision is taken at a special meeting called, solely, for that purpose.

Any such decision must be approved by a majority of the remaining members of the Committee of Management, in accordance with Rule 41.5.

8.2

Record retention

A record of the outcome of an investigation (whether the complaint is upheld or not) will be retained in the Committee of Management member’s file for no less than 12 months.

8.3

Notification to SHR

The outcome of any investigation will be notified to the Scottish Housing Regulator, in accordance with the requirements of the notifiable events statutory guidance.

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Appendix 1 Template Description of Oversight Role The Chair and Vice Chair will be responsible for overseeing the investigation.

Their responsibilities include:  Agreeing the brief for the investigation  Appointing a suitably qualified/experienced person to conduct the investigation  Agreeing a timetable for the investigation that balances the need for thorough investigation with the importance of resolving the matter and reaching a conclusion without undue delay  Ensuring that all necessary correspondence and communication is issued to the GBM(s) involved in the investigation  Ensuring that the SHR is kept informed, in accordance with their requirements  Overseeing the investigation to ensure that timescales are met, the brief is fulfilled and the report contains all necessary information  Ensuring that the necessary arrangements are made for the Committee to consider the report and its conclusions and to agree a consequent course of action, appropriate to the findings – which may or may not uphold the complaint(s)  Advising the GBM(s) who is/are the subject of the complaint(s) of the outcome of the investigation, the decision of the Committee and any proposed action

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Appendix 2 Template Letter to Inform Governing Body Member of an Investigation This template should be customised to reflect the particular circumstances. Ideally, the governing body member will have been made aware of the issue by the Chair (e.g. by telephone) and the letter is to confirm and formalise the process. It would be appropriate to refer to the terms of any such phone call e.g. be referring to agreement to take leave of absence and not to discuss the matter.

Dear Allegation of a Breach of the Code of Conduct I write to inform you of the Committee’s intention to commission an independent investigation into an alleged breach of the Code of Conduct.

The Committee has been made aware that it has been alleged that you [insert details, including the relevant section(s) of the Code].

This allegation must be independently investigated. The Committee is aiming to conclude the matter by [insert target completion date]. Until the outcome of the investigation is confirmed, it is expected that you will take leave of absence from the Committee and you should not discuss the matter with anyone other than the Investigator or someone who will accompany you to any meeting(s) with the Investigator.

Your e-mail address [or other contact details] will be provided to the Investigator so that they can contact you. I will confirm the appointment of the Investigator as soon as possible. I trust that you will co-operate fully with the investigation.

The Committee is being informed today of the allegation and your leave of absence, as is the SHR. Your sincerely

Chair WGHC Committee of Management

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Appendix 3 Brief for the Conduct of an Independent Investigation Allegation of a Breach of the Code of Conduct Background: [insert details of the concern / allegation or complaint] The Committee member has been informed of the allegation and has taken leave of absence.

The SHR has been notified.

Purpose and Scope of the Investigation: To investigate an allegation that [specific allegation e.g. breach of confidentiality; unacceptable behaviour] and to report to the Committee of Management on the findings and conclusions.

The investigation should establish the facts of the allegation, determine whether or not the allegation is substantiated and determine whether or not a breach of the Code of Conduct may have occurred. The investigation should report on whatever facts and circumstances are relevant to the allegation and should identify the conclusions reached. The final report should include a section that can be extracted and used in communication with those whose conduct is being investigated, at the conclusion of the process.

Conduct of the Investigation: The investigation should be conducted by means of [e.g. a desk-top review of relevant documents and interviews with relevant people (who should be defined)].

All interviews will be conducted by [e.g. in-person meetings, phone or video-conferencing] and the report will be presented to the Committee of Management [e.g, date of the meeting or virtually]. Liaison with WGHC and its representatives will be via [insert details eg, telephone, other virtual means, meetings].

Two members of WGHC’s Committee of Management (including the Chair) will oversee the conduct of the Investigation; they will be supported by [insert relevant Officer], who will be the primary point of contact for the Investigator.

The Investigator will have full access to all relevant documents and WGHC will assist with administrative arrangements relating to the conduct of the investigation.

Timescale: [Specify, including dates by which any drafts are required and taking account of the Protocol’s expectation that investigations should be concluded within six weeks] For Independent Investigations: A suitably experienced person is required to undertake an investigation in accordance with this Brief.

Proposals should be submitted which outline your experience of similar assignments, your availability and capacity to meet the required timescale and your anticipated fee. Details of potential referees should also be provided (WGHC will inform you before approaching any referee) Please submit your proposal to [insert details] by [specify]

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