The CCT Code of Conduct

The CCT Code of Conduct is one of the ways we put CCT’s values into practice. It’s built around the recognition that everything we do in connection with our work at CCT will be, and should be, measured against the highest possible standards of ethical business conduct.

Our values are:

  • Transparent
  • Progressive
  • Everything is possible

The requirements of this Code apply to all employees, Board Members and Advisers, along with contractors and consultancies engaged to carry out work for the organisation (hereafter all described as Employees for the purpose of this Code of Conduct).

Behaviour

Our values are fundamentally about doing good for others first and as a result our own success will follow. In pursuit of this we strive to conduct all activities with honesty and integrity and to the highest ethical standards. Underlying behaviours we exhibit to help inform our values include:

  • A passion for excellence and quality fit for the purpose
  • Dynamic and action oriented with a sense of urgency to get the job done in good time
  • Collaborative (internal and external)
  • Customer and solution focused
  • Giving (of value – with the long term relationship in mind)
  • Committed (to make a difference)
  • Driven to continually improve ourselves, help others and improve our organisation

We can only realise the vision through our Employees and it is therefore essential that all personnel conduct themselves according to the highest standards of behaviour, in the most professional manner and with a commitment to perform work to the best of their individual and collective ability.

CCT recognises the obligations towards its customers, its employees, its partners, suppliers, to the community as a whole and all others with whom it interacts.

We seek to fulfil those obligations according to the principles laid out below.

Principles

Selflessness

Employees should take decisions in the best interest of customers, partners and the organisation. They should not do so in order to gain financial or other material benefits for themselves outside of their rewards expressed in the contracts of employment. Staff should work primarily digitally wherever possible, and do their work on the specified systems to fulfil their role and collaborate with others to fulfil theirs efficiently and effectively. This practice also protects the information and assets from risk of loss and heightens productivity with a ‘produce it once, use many times’ philosophy.

Integrity and Honesty

Employees should not place themselves under any financial or other obligation to outside individuals or organisations that might influence them in the performance of their official duties.

We want to celebrate achievements, learn quickly from success and failure and be honest about our strengths and areas for improvement. Employees need to be honest with each other and also look to drive up standards for themselves and others. It’s a trait of top performers.

We operate in a high performance challenging environment with limited resources however will continue to invest in the careers of our staff, but cannot afford to carry passengers or non performers. Our view is that integrity and honesty also extends to supporting staff to perform well, and having difficult yet honest conversations too when they are required, especially if trust and confidence in delivery falls below acceptable standards.

Objectivity and Openness

Employees should make decisions objectively and wherever possible openly (subject to business sensitivity) with clear criteria underpinning their decisions in a fair and impartial manner both internally and externally.

Responsibility and Accountability

Employees are responsible for their actions and accountable for their decisions and behaviours to their colleagues, customers and partners.

Leadership and followership

CCT operates with self-organising teams and gives Employees the opportunity to grow and develop. Everyone has the potential to be a leader, irrespective of hierarchy, and should feel confident in stepping up to demonstrate that whenever and wherever the situation arises, internally or externally. Followers, regardless of organisation hierarchy, should also respect and support their leaders and demonstrate the values of the business in working together for the right outcomes.

Business Conduct

CCT’s commitment

We will manage business according to its ethical values, to the highest standards of integrity, behaviour and business practice. We will work with others in a spirit of co-operation and will develop relationships based on honesty, fairness, value and mutual trust. This commitment manifests itself in all forms of communication including verbal and written mediums.

The behaviour of Employees is central to how we conducts business. We will ensure the resources are in place to enable Employees to realise the delivery of services in line with the values and vision. In particular we will to be an employer of choice through the creation of a positive, responsible, innovative, open, honest and challenging working environment in which ability and delivery is valued, encouraged, developed, recognised and rewarded.

We will provide a professional, safe and healthy environment for the workforce demonstrated through its efforts to achieve and retain recognised accreditations including but not limited to International Standards and local health and safety laws.

We will protect the integrity, availability, and confidentiality of all personal and corporate information held by us in either manual or electronic form as evidenced in gaining standards such as ISO 27001 along with other relevant certifications.

We are committed to equality and inclusion in all business, HR and technical policies, controls and operating procedures.

We respect the right to privacy and data protection within the Data Protection Act 2018 and, GDPR and the Human Rights Act 1998. When staff are absent for long periods (outside holidays) or there is a disaster, we reserve the right to contact staff at home or access their work email, other systems and office held files.

The Employees’ Commitment

All Employees must respect, exhibit and encourage our values and vision set out above, along with the principles in this Code and set out elsewhere in the relevant policies of the ISMS. This Code along with the relevant contract of employment and specific policies and guidance set out the standards expected of all Employees.

It is the personal responsibility of every Employee to act in accordance with this Code and the policies. If they are unable to do so for whatever reason they must raise that with their line manager immediately when appropriate interventions can be considered.

All relevant policies can be found in our HR system and communications groups environments. Employees have a responsibility to ensure that they understand the objectives incumbent upon them and all the policies.

All employees are required to take responsibility for their own work and the proper performance of anyone they manage.

All employees must perform their duties diligently and as directed by their manager.

All employees have a duty to their employer not to act in a manner that prejudices the health and safety of another employee, customer, partner or anyone else. Employees should also raise concerns to a Director if they suspect fraud, bribery or any other abuse of a position held by work colleagues.

All employees must comply with the terms and conditions of their contract of employment and the policies specified in our Information Security Management System. All employees must avoid engaging in activities that are likely to breach that contract or bring disrepute or damage upon the organisation, even where such conduct occurs outside of work.

Employees must not do anything while on or off duty that could harm the organisation’s reputation and/or lead to criminal charges against them. This includes verbal or written communications and general work practices, including email and social media activity that breaches policies, legislation or regulation.

Employees should be aware that failure to adhere to the principles contained in this Code, and/ or any policy, legislation or regulation applicable to their employment may be considered a disciplinary matter, and under certain circumstances can bring about instant dismissal.

Additionally all managers must:

  • Ensure that the requirements outlined in this Code are met including ensuring that employees are aware of them.
  • Ensure that appropriate, fair and consistent action is taken to deal with any failure to conform to them, in accordance with the appropriate procedures.

Raising concerns

It is essential that everyone working for the organisation feels able to raise any concerns they have about the way business is being conducted in a manner that is simple, effective and confidential. We will ensure employees feel able to raise concerns without fear of any reprisals being taken against them including making available no blame review sessions and anonymous reporting as set out in the relevant policy areas.

Concerns can be raised about any aspect of the organisation’s activities, e.g. fraud or financial impropriety, harassment, bullying, discrimination; health and safety, decisions, actions, conduct or communications that are unlawful, in breach of policies or in significant breach of our values and vision.

Any concern that an employee has should ideally be discussed in the first instance with their manager, or someone else with senior management authority within the organisation.