On 3 May 2022, the National Housing Federation (NHF) published its new and updated Code of Conduct (the 2022 Code). It can be downloaded – for free! – from the NHF website here.
The 2022 Code replaces the NHF Code of Conduct 2012 (the 2012 Code) and sets out the baseline standards that the NHF expects of its member registered providers (RPs). It is intended to be read in conjunction with the 2020 Code of Governance (Code of Governance), which was published in November 2020. Most RPs will have adopted the 2012 Code (and the Code of Governance) and will need to take steps to formally adopt the 2022 Code.
The biggest change between the 2022 Code and its predecessor is that it’s much shorter and less prescriptive. Whereas the 2012 Code offers 70-something pages of in-depth requirements and instructions, the 2022 Code is 19 pages (13 when you exclude the index and introduction!) and is more geared around embodying key themes rather than setting out specific instructions. For example, there is a new requirement to strive to avoid or reduce negative environmental impacts and whilst the 2022 Code doesn’t offer any further insight into this requirement it is clearly reflective of current environmental concerns.
The 2022 Code will normally apply to staff and board members and may include certain volunteers, involved residents and contractors depending on their level of involvement. It will be up to each RP to decide to whom the Code applies.
RPs are afforded more freedom to decide how to apply the 2022 Code’s requirements to their organisation, bearing in mind their size, culture, governance and circumstances. There is no longer any requirement to complete an annual ‘compliance checklist’. The box-ticking approach of its predecessor has been jettisoned to avoid the administrative burden of evidencing every individual’s compliance as it could apply to hundreds of people. Instead, boards are asked to adopt the Code and share the Code with those affected. It is a requirement of the 2022 Code that all affected people have access to all of the RP’s policies and procedures.
The NHF acknowledges that some RPs may wish to seek further assurances in relation to Code knowledge and compliance and states that it will be down to individual RPs to decide on how best to approach this, for example, an approach similar to HR case reporting may be considered appropriate for complaints made under the 2022 Code so that the board can understand compliance.
The four themes covered in the 2022 Code are summarised below:
- Acting in the best interests of the housing association and its residents. Individuals should seek to further the housing association’s strategic objectives, and not act in any way that is discriminatory or gives rise to a conflict of interest. When representing the housing association, individuals should not act in a way that brings the association into disrepute.
- Behaving with integrity. Individuals must declare any potential conflicts of interests or relationships with residents as soon as possible, they must not use their position for any personal gain, take part in any acts of bribery, or disclose confidential information.
- Conducting yourself professionally and treating others well. Individuals must promote cultures that are welcoming, accepting and accommodating towards people of all backgrounds, and must act professionally in all dealings with residents.
- Protecting yourself, other people and the environment. Individuals must not knowingly put themselves or others at risk and must strive to avoid or reduce negative environmental impacts.
For more information
If you have any queries about the 2022 Code, please contact Catherine Simpson.
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