CLV Group Code of Conduct

About Our Code of Conduct

Campus Living Villages (CLV) is committed to the highest standards of ethics, integrity, and compliance in all aspects of its business, across all of its villages, regional and corporate offices. Our Code of Conduct is the foundation on which this commitment is built. It provides information and answers, to help us model our values and sets the standard for doing the right thing when acting on behalf of any CLV group company.

The purpose of the Code of Conduct is to:

  • Promote honest and ethical behaviour
  • Maintain CLV’s integrity
  • Set out responsibilities and accountabilities
  • Ensure compliance
  • Protect and promote the interests of our employees, workers, village residents, university partners and other stakeholders – while always complying with the law in the regions in which we operate

The Code of Conduct extends to all employees, directors, contractors, and consultants of CLV in the performance of their duties (or provision of their services).

John C Schroder, Group Managing Director and Chief Executive Officer

 

Our Core Values

Our goal is to CREATE a culture that we all enjoy working within, and our values reflect what we believe in and how we behave:

Community

Be part of the ONE team and pursue the team goal

Respect

Be tolerant and accepting of colleagues and customers and do not manipulate, demean or mistreat people

Equality

Endeavour to treat everyone the same, regardless of their role.

Accountability

Work hard, work smart and do not blame others

Trust

Be forthright, candid and deliver on your promises.

Enthusiasm

Be passionate in what you do and give 100%

3.0 | Principle of Our Code

This Code of Conduct outlines how we expect people to behave. Use it to guide your actions and to identify the resources available, including a range of Group and Regional Policies and Procedures, to help you navigate ethical issues. Revisit it often to refresh your memory on key topics.

A | Making Good Decisions

The Code of Conduct can provide practical guidance for many situations; however, no single document can anticipate every situation or outline every requirement

B | Conduct Business Legally and Ethically

Read, know, and follow the Code of Conduct, and comply with applicable laws and regulations in the region you work within

D | Ask Questions

The Code of Conduct is just the starting point. It establishes basic expectations for how we are to

conduct ourselves in the workplace; but it does not have the answer to every question or every situation. If you are unsure of which policy to follow, seek guidance on policies to be used, and actions that may be appropriate, if you are unsure at any stage, or if you believe there may be a conflict between a company policy and local legislation, ask People and Culture

C | Know the policies and procedures that apply to your job

Please refer to your Group and regional policy library for the most up to date policies and procedures or reach out to People and Culture if you have any questions. CLV Group has mandatory compliance training in place on CLV’s Online Learning Academy. This training will help you understand Group policies and procedures and apply them in your everyday work. Each region may have additional mandatory training on other platforms, that must be completed within established timeframes

E | Speak Up

We are all trying to get things right together. Speaking up means asking questions so we can ensure we are living up to the high standards that we set at CLV. CLV is committed to listening to all concerns raised. Speaking up is not just welcomed and appreciated, it is an obligation we all have to each other. If you see or suspect a contravention of the Code of Conduct, say something. Every employee is accountable for upholding the

Code of Conduct. We all have a responsibility to report improper conduct, in good faith and to the appropriate individual. By doing so, we help CLV maintain a positive work environment

4.0 | How We Do Business

4.1 Sustainability

We are committed to embedding sustainable, responsible and social practices throughout CLV. We are focussed on providing a sustainable built environment and a supportive and inclusive community for our residents. Our business is built on integrity and corporate responsibility.

4.2 We celebrate diversity and inclusion

We are passionate about providing our employees, workers, village residents, university partners and other stakeholders with a positive experience. Each of us brings a different perspective to support that passion. It is our diversity of backgrounds, cultures and viewpoints that helps drive our success and ensures that we live up to our full potential. We respect the individual experiences, cultures and perspectives of everyone on our team.

4.3 We respect all and treat everyone equitably

CLV is committed to providing a workplace which is free from bullying, harassment, unlawful discrimination, sexual assault, and sexual harassment. We aim to ensure all those participating in the workplace are treated with respect, dignity, and fairness with the aim of creating an environment that promotes positive working relationships. At CLV, employees are expected to treat everyone fairly and without prejudice, discrimination, or harassment. We value and encourage diversity in opinions and viewpoints and encourage employees to respect and take into consideration the opinions of others, working collaboratively to reach department and company goals.

4.4 We maintain a safe & healthy workplace

We strive to work in a healthy and safe manner. We are committed to providing our employees with a healthy and safe work environment that complies with all applicable occupational safety and health laws and standards.

We also conduct business in a way that respects the health and safety of our customers and residents and the communities in which we operate. Safety is every employee’s responsibility, and this requires all employees to be safe in their actions and to assist others. Whenever there is a workplace injury or a hazardous situation, it is an employee’s responsibility to follow the Group Incident Reporting Procedure and immediately alert your on-duty manager. Where escalation is required (level 3 or 4 incident, or a hazard threatening safety) and you cannot reach the on- duty manager, you must escalate up the management line until contact is made.

Acting promptly allows CLV to conduct a timely investigation and take any appropriate action to resolve the issue. Upon learning of any circumstance that might affect health and safety in the workplace, managers must act immediately to remove the potential risk.

We do not tolerate the illegal use of alcohol and/ or drugs or other substances on any of our premises or on university grounds.

We have a zero tolerance for threats of any kind, fighting, or other acts of violence against employees, customers, visitors, or guests by any person (including shouting). Illegal weapons or anything that could possibly be deemed to be an illegal weapon (including personal defence items) and explosives are absolutely prohibited from all CLV properties (whether they be owned or managed for third parties including our university partners).

4.5 We conduct business honestly and ethically

CLV expects that all employees will conduct business honestly and ethically and in line with the current policies.

Human Rights

We respect human rights and support global efforts to protect them. We evaluate and address human rights issues within our business operations and in the communities in which we operate including:

  • Following all employment laws and regulations, including rules about the employment of children, and supporting equal opportunities and the elimination of discrimination in employment.
  • Striving to ensure that child labour, human trafficking or other illegal, abusive, or forced labour practices have no place within our operations, anywhere in the world.

Privacy of Others

People – inside and outside of CLV – trust us to handle their personal information with care and to use it appropriately and only for the purposes provided. We respect the basic right to privacy of our employees, customers and other third parties and only use personal information when needed to operate effectively and in compliance with the law.

We must all take reasonable steps to ensure that we:

  • Collect only the personal information that we need for our business purposes.
  • Be open and honest about how we collect, use and disclose personal information.
  • Take appropriate measures to keep such data secure in accordance with our policies and procedures.
  • Use data in accordance with the GDPR in the UK.
  • Take the appropriate and required training to understand our privacy obligations and comply with regional Privacy Policies.

Preventing Bribery and Corruption

CLV prohibits all forms of bribery and corruption. We will not give, receive, or promise anything of value that could even appear to improperly influence a decision by us or someone else. Instead, we will deal with our customers and all third parties in an honest and straightforward manner. Acts of bribery and corruption are simply not part of the way we do business.

Know a bribe when you see one

Recognize that a bribe can take many forms – including payments, favours, charitable or political contributions, Sponsorships, gifts, meals, entertainment, or travel. Appearances matter. Even if your intention is honourable, sometimes, just the appearance of impropriety may have negative consequences. If in doubt, ask your line manager or P&C representative.

Money Laundering, Tax Evasion & Illicit Financing

We share a responsibility to watch for signs that third parties may be trying to use our products and services for money laundering or illicit financing. Money laundering is an essential part of many criminal activities, so it receives considerable attention from governments, international organisations and law enforcement agencies around the world.

Illicit financing activity includes activity by or for terrorist groups, focuses on the destination and use of funds. In this case, the money may come from legitimate or criminal sources, or a combination of the two.

Tax evasion refers to the use of intentional and illegal means to avoid paying taxes or helping anyone else to do so. Each of us must not participate in any illegal or deceptive practice that would result in tax evasion and immediately report any such practices we become aware of.

CLV is committed to cooperating fully with law enforcement and regulatory investigations concerning possible money laundering, tax evasion or illicit financing activity. If you are approached by law enforcement or a government agency concerning any of these, immediately contact the Legal Department, or a member of the Regional Executive Team.

4.6 We act in the best interests of CLV

Conflicts of interest

All employees are expected to avoid being in a situation in which themselves, their families, external interests or activities, conflict or could potentially conflict with the best interests of CLV or interfere with their obligations to CLV.

Other that in the ordinary course of business, an employee must not use their position at CLV to benefit any other business or person outside CLV, or to benefit themselves independently of CLV’s business.

Understand the rules about gifts & entertainment

All employees must exercise due care and discretion when giving or receiving business related gifts including any payments and incentives from third parties that may compromise decisions or judgements or create business obligations on the part of the recipient. All employees should always comply with the current policies.

Connecting responsibly through social media

Social media offers a great way to exchange ideas and build relationships but be smart and use it in a way that is consistent with our values and our policies. Because of the risk for improper use, however, we have adopted a few key guidelines to follow when posting to social media:

  • Keep our confidential and proprietary information secure, remembering that the internet and other media channels are a public place
  • Never post disparaging or misleading statements about our partner universities, competitors or any person
  • Use the Code of Conduct, our policies and our values as your guide
  • If in doubt, don’t post

Responding to enquiries

Every word you speak, write or share about CLV has an impact on our reputation, our brand and our people. That’s why only a few people are authorized to make official statements about our company to the public. We want to make sure that information that is communicated about CLV is reliable, consistent and accurate.

Unless you are specifically authorized to represent CLV, do not respond to inquiries from investors, the media, our partners, or the public. Refer inquiries like these to the regional executive team (RET) in your region.

Be careful with your communications

Make sure that your communications are both necessary and appropriate when communicating with those inside or outside of CLV. Whether casual or formal, communications should never contravene our policies or the law. Never harass others, write, transmit, or view anything inappropriate or illegal, or interfere with network users, services, or equipment.

Do not assume that your communications are private. Anything you create, send, or receive on our systems may be accessed, monitored, or reviewed by CLV, except where prohibited by law.

In every business communication, verbal, written or digital – use good judgement.

Ask yourself:

  • Would I be comfortable seeing this published in a newspaper or on social media?
  • Am I being factual, professional and polite?
  • Have I chosen my words carefully, and made sure they are accurate?
  • Have I avoided the use of sarcasm, exaggeration and speculation?
  • Have I limited distribution to those who need the information?
  • Would I be comfortable seeing this as an exhibit in a court proceeding?

4.7 We safeguard our company assets

Protecting our assets

Just about everything we use to do our jobs every day could be considered company assets, and each of us is responsible for protecting them from theft, loss, waste or abuse.

Inappropriate use or a failure to protect assets can have a direct negative impact on our ability to do business efficiently and profitably.

In general, you shouldn’t use CLV’s assets for your personal activities. Occasional personal use of things like email, internet access and phones are okay as long as it is limited, doesn’t interfere with your work (or anyone else’s); doesn’t contravene the law or our policies; doesn’t cost CLV anything and isn’t for personal gain or political purposes.

Information and Data Security

In the course of your employment at CLV, you may have access to a variety of information that we refer to as “Business Information.” Depending on the type of information, there are specific precautions we must take to protect CLV, other employees, stakeholders and customers, and, in many cases, ourselves from the unlawful and inappropriate use or disclosure of that information.

Always keep in mind, that access to Business Information does not give you permission to disclose that information, but you do have a responsibility to protect it. You must not disclose Business Information to anyone except for reasons strictly related to your authorized job duties, and share this information only with other employees who have a legitimate “need to know.”

Our Books and Records

Complete and accurate records

We are committed to maintaining complete and accurate financial records in order to make responsible business decisions and provide complete and truthful information in compliance with applicable legal disclosures.

All CLV transactions must be accurately and fairly recorded to allow proper preparation of our financial statements and to ensure full accountability for all of our assets and activities.

Accounting and financial reporting practices must be fair and proper, in accordance with, accounting principles for each of the regions CLV operates in. Appropriate records must be kept of all transactions and handled in accordance with the applicable data retention policies.

Each of us must refrain from any misleading or deceptive financial practice and report immediately any such practices of which we become aware.

Each of us is responsible for ensuring that the appropriate approvals, signatories and execution procedures are followed in connection with all transactions in which we are involved and for abiding by our own personal authorization limits and for complying with CLV’s internal accounting policies, financial authorization and internal control processes.

If you have any questions about authorization requirements or limits, please contact the Finance department.

Company assets

CLV trusts you to use its assets for CLV business use and to take good care of them, protecting them against theft, fraud and unauthorized use.

We are responsible for using company assets appropriately

  • Use facilities, vehicles, equipment and other physical assets, including corporate credit cards, only for authorized purposes that are related to your job responsibilities.
  • Never take part in any action that involves fraud, theft, misappropriation, embezzlement or similar illegal activities. Use email, internet, phone and other communication systems for business purposes—keep personal use to a minimum.
  • Never use our systems in ways that could be perceived as illegal, harassing or offensive, or that could reflect poorly on CLV. This applies any time you use CLV equipment, both during and outside of working hours and while at work or at a remote location.

Intellectual Property Assets

Each of us has an obligation to protect the Campus Living Villages name by following our brand standards and by reporting any misuse, whether internally or externally. Intellectual property refers to trademarks, patents, copyrights, proprietary technology and trade secrets and other proprietary information, including business and marketing plans.

Always use our intellectual property properly, checking with the Legal Department before allowing third parties to use our intellectual property. Respect the intellectual property of others; do not use others’ intellectual property without their authorization or without permission from the Legal Department.

CLV owns all intellectual property rights in any materiel created, generated or contributed to by employees in connection with their employment or engagement with CLV.

As a condition of employment, all employees waive all moral rights for the benefit of everyone in respect of any existing or future intellectual property created by them alone or with others in the course of or in connection with their employment or engagement with CLV.

4.8 We value Corporate Social Responsibility

We value diversity in all aspects of our business operations, including providing our products and services to our customers and the communities we serve.

Personal community activities

We are free to support community, charitable, and political organisations and causes of our choice, if we make it clear that our views and activities are our own and not representative of CLV.

Political activities

CLV respects your right to engage in personal political activities, but again, you must do so on your own time, with your own resources. You are not permitted to use CLV time, property or equipment for personal political activities without prior authorization.

Environmental

As a responsible corporate citizen, CLV is committed to practices that minimize our use of natural resources. We strive to conduct our business in an environmentally sound manner based on our business and customer needs and regulatory requirements. As part of this commitment, we must all follow all applicable health, safety, and environmental laws and regulations.

4.9 We safeguard CLV’s reputation

All employees must serve CLV diligently and to the best of their ability. Carry out all lawful instructions and discharge such duties and functions as may be delegated or assigned to them by their mangers including work for any related, associated or subsidiary companies, and any joint ventures with which CLV may be associated.

Compliance with Laws, Regulations, Policies and Procedures

CLV requires and expects its employees to:

  • Comply with all laws, rules and regulations that apply to CLV in the conduct of its business and affairs
  • Abide by all applicable rules and standards of any bodies empowered to regulate the industries in which CLV operates
  • Comply with all contractual obligations and other undertakings without attempting to evade or delay compliance
  • Abide by all protocols, policies and procedures of CLV, this Code of Conduct, and as otherwise advised, notified or made available to you.

Excellence in Performance

CLV strives for and promotes excellence in all its activities. Ongoing and sustained success and growth of CL V is very much dependent on the consistent achievement of excellence and quality in all company operations. This can only be realized when all employees adopt the aims of consistent quality and excellence in results and performance.

Dress and Presentation

All employees are expected to present themselves at all times in a manner which is consistent with CLV ‘s image as a professional organisation. This may include full business attire during relevant meetings with external stakeholders on any given day. Where required, employees are to complete their shifts in CLV uniforms provided. When in uniform, all employees are highly visible ambassadors of CLV and should behave accordingly.

If at any time you are unsure what is or isn’t appropriate attire, then you should discuss this with your line manager.

Personal relationships

Employees are encouraged to socialise and develop professional relationships in the workplace, provided that these relationships do not interfere with the work performance of either individual, or with the effective functioning of the workplace. Employees who engage in personal relationships (these include romantic or physical, current or past, isolated or continuing) must be aware of their professional responsibility to immediately make their line manager(s) aware of the relationship. Both parties are responsible for assuring that the relationship does not raise concerns of favouritism, bias, ethics and conflict of interest.

Romantic or physical relationships between employees, where one individual has influence or control over the other’s conditions of employment, are inappropriate. These relationships, even if consensual, may ultimately result in conflict or difficulties in the workplace. If such a relationship exists or existed, they must be disclosed to P&C and/or your line manager immediately. CLV reserves the right to assess potential conflicts and may make changes in roles or reporting lines if deemed required.

4.10 Reporting behaviour or conduct that contravenes the Code of Conduct

We expect Employees to raise any incidents or behaviour that contravenes the Code of Conduct. Reports should immediately be made to a supervisor or manager and/or the People and Culture Team.

5.0 | Regional Variation

In the USA, nothing contained herein shall create contractual rights on behalf of the employee or change an employee’s status from employment at will.

CLV Group Code of Conduct Endorsement

The CLV Group Code of Conduct has been endorsed by the Executive Committee and approved by the Board of the Campus Living Villages Group.​