Ethical Practice Policy

This policy is designed to embody the core values implied in our mission statement.   These are: freedom, high professional standards, continuous self-improvement and accuracy.  The structure of the policy is derived from the Institute of Business Ethics’ issues-based Code of Business Ethics. The following general principles shall apply:

·                                            The Ethics Policy applies to all MAEL directors and employees and anyone acting on their behalf

·                                            All personnel are required to be familiar with the Ethics Policy and apply it in their everyday work

·                                            Failure by any MAEL employee to comply with the Ethics Policy may result in disciplinary action in accordance with the published policy

·                                            The obligation to comply with the Ethics Policy shall be incorporated into contracts with third parties

·                                            Employees must report unethical behaviour to an appropriate senior manager or director, each of whom shall pass the matter on to the CEO to investigate in accordance with the policy on investigations

·                                            All reports of violations will, insofar as is practicable, be kept confidential

·                                            MAEL will not tolerate retaliation against any employee because they have made a report in good faith regarding a genuine suspected breach or violation of the Ethics Policy

 

Specific ethical policy issues are itemised below (the order does not reflect the importance of any issue):

 

Compliance with Applicable Law

 

MAEL complies with all laws and regulations wherever it operates.  Where they are considered by us to be inadequate or ambiguous, our aim is to set a high ethical standard exceeding the basic requirements of applicable law.  Breaches shall be reported to the MD who will ensure future actions do comply, by either modifying a policy or procedure or disciplining any staff member found to be in breach of company policy.  Policy modification shall follow the standard procedure.

 

Competition

 

MAEL is committed to vigorous, lawful, straightforward and ethical competition. We ensure that our business practices fully comply with the competition laws wherever the company does business.  In particular:

·                                            MAEL does not engage in any contacts with competitors where prices, markets or customers are discussed.

·                                            MAEL competes based on the merits of its products and services and ensures that its materials, advertisements and other communications accurately and fairly describe the products and services – see also the Fair Dealing (Advertising) policy statement.

Breaches shall be dealt with as if they were breaches of applicable law (v.s.) whether or not they are in the country of operation.

 

Bribery

 

MAEL personnel must never offer, give, accept or receive a bribe in any form. The following may be indicators of corrupt activity:

·                                            Insufficient, false, or inconsistent information provided by the person

·                                            Cash/wire transactions or requests that are not consistent with the business activities of the person/organisation

·                                            A request by a person to structure a transaction to evade normal record keeping and/or reporting requirements or to structure it in a way that appears to have no legitimate business purpose

·                                            Requests for or unusual fund transfers coming from or going to countries with strict banking secrecy laws or weak anti-money laundering controls or where crime and/or corruption is widespread

·                                            A reluctance by the person concerned to provide any information requested for proper identification

·                                            A person opens a number of accounts under one or more names and asks for payments to be distributed among those accounts or deposited in those accounts in small increments, or requests payments through a third party (other than a bank) that has no contractual relationship with MAEL

·                                            Payments for large amounts by way of money orders, travellers’ cheques or cash

·                                            When there are traces or signs that the person is not acting on his own behalf, but is trying to conceal the true beneficial owner’s identity

·                                            Transactions with persons with unknown addresses, post office addresses, or with those who provide insufficient or false information

·                                            Transactions which have shell companies as middlemen, especially those domiciled in secrecy havens, or transactions involving several individuals and companies where there is no apparent relationship

·                                            Transactions where money or property is passed through a consultant or representative to a public official to obtain certain government actions e.g. ‘facilitation payments’

·                                            Use of consultants or representatives who are closely connected with the government or a political party of the country in which MAEL is doing business

·                                            Gifts or gratuities to government officials, political party officials, candidates for public office, customers or to their families, including extravagant entertaining of government officials, party leaders, customers or their families

·                                            Indirect payments to customers, government officials or their families

·                                            Requests for unusually large commissions, retainers, or other fees

·                                            A request from an agent or a representative for an unusual method of payment or payment to be made in a third country

·                                            Appointment of a contingent fee representative when a qualification decision is imminent

 

Gifts and Entertainment

 

Provided that an employee uses good judgement and moderation and that the recipient’s objectivity is not influenced, gifts of a nominal value or modest and reasonable entertainment to further a business relationship are generally acceptable.  This implies that gifts neither make the recipient feel obligated nor could be construed as a means to make the recipient feel obligated.  Within that context, an MAEL representative may offer or accept any gift which either individually or in aggregate, taken over a twelve month period, does not exceed £250 GBP. For these purposes, gifts from different people within the same organisation should be aggregated.

 

Entertainment may only be offered or accepted in the ordinary course of business provided it is reasonable and modest and neither influences the recipient’s objectivity nor could be construed as a means to make the recipient feel obligated. If in doubt whether the entertainment is reasonable and modest, prior approval from the line manager or appropriate director.

 

Conflicts of Interest

 

Potential conflicts of interest must be avoided or, if unavoidable, carefully managed. In all cases they must be disclosed to the line-manager and discussed openly, promptly and straightforwardly and must also be documented in writing.  Dealing with actual or potential conflicts is dealt with more fully in the Conflict of Interest policy which must be consulted and observed.

 

Use of Company Assets

 

Company assets, including its intellectual property, are solely to be used for legitimate company business purposes. Employees may not use Company assets for personal gain or personal business, nor may they allow any other person, not employed or authorised by MAEL, to use them.

 

Safeguarding Important Information

 

All employees must take appropriate steps to protect confidentiality and respect confidential information belonging to others.  MAEL is registered with the Data Protection Agency and fuller details are to be found in the Fair Dealing (Data Protection) policy (see p. ).

 

Political Involvement and Contributions

 

MAEL is not a political organisation. The company does not make any contribution, whether in cash or in kind, to any political candidate, political party or organisation whose activities are designed to promote the interests of political parties or political ideologies.  The company is also not affiliated to any religious persuasion and does not make any contribution to any religious organisation for the purpose of promoting that religion’s interests.

 

The Application of Human Rights Standards

 

MAEL seeks to increase awareness of human rights, and particularly children’s rights, issues throughout the organisation. The company is also a supporter of the Montessori Europe Declaration of Prague, which has particular reference to the rights of children and is appended to this policy statement.  MAEL takes seriously any allegations that human rights are not properly protected within our sphere of influence or that we may be complicit in violations.  In the event of any such allegation, the CEO will undertake an investigation to establish the facts and bring a report (with proposed actions) to the MD for the next director’s board meeting.  Should immediate action be indicated, then the CEO will undertake that, in consultation with the MD, and include that in his/her report.

 

Environmental Responsibilities

 

The Company gives highest priority to the health, safety and security of all its

employees and to the protection of the environment.  Any personnel involved with processes that affect the environment must perform his or her job in a manner consistent with our values, policies, standards, guidelines and procedures.  Every MAEL employee has the obligation to act, either directly or by reporting to management, whenever he or she believes that violations of environmental policy, law or regulation are occurring.

 

Accuracy of Advertising

 

All advertising must be accurate.  Please see the separate advertising policy.

 

Representations regarding Qualifications

 

All MAEL employees and all Teaching Centre staff must ensure total clarity as to the accredited/regulated status of any qualification.  No statements shall be made which might mislead stakeholders or users of qualifications as to the qualification’s status.

 

 

 

This implies, specifically:

·                                            Any qualification which is Ofqual regulated will bear the Ofqual logo on the certificate, will be specified as regulated on the transcript (with the website address for verification) and described as ‘Ofqual-regulated’ in any advertising copy.  Any qualification which is not Ofqual-regulated will not have the Ofqual logo on the certificate, will have the statement ‘not an Ofqual-regulated qualification’ on the transcript and will carry no reference to Ofqual on any advertising copy.  Any notice of revision must be acted on.

·                                            Any qualification which is credit-rated by the Open (or other) University will carry that information on the transcript (with a website address for verification) and any advertising copy may state ‘University recognised’.  Any qualification which is not OU recognised will bear no reference to the OU on any documentation or advertising copy.

·                                            No MAEL qualification may be described as MACTE accredited or recognised.  Even though the syllabus may meet the relevant MAC TE standards, care must be taken not to give the impression that that is sufficient for accreditation.  Any teaching centre which has independently applied for or been granted MACTE accreditation, may use the form of words specified by MACTE in its advertising copy.  However, care must be taken to ensure that no impression is given that MAEL is so accredited.

·                                            MAEL qualifications may not be described as ‘Montessori Europe accredited’, but it acceptable to describe them as conforming to the criteria in Montessori Europe’s declaration of Gothenburg.

·                                            The approval of MAEL qualification(s) by any other body may be described in promotional material, but the appropriate form of words (if possible using words approved by that body) must be used.

 

MAEL will not advertise or promote its qualifications in such a way as might lead to users of the qualifications being misled.  Teaching Centres are required to submit advertising copy to MAEL for approval before publicising it.  The MD will check the accuracy of the copy, but not dictate any design used.  Failure to meet this requirement may lead to the Centre being sanctioned.  This section of the policy will be directly monitored by the MD, through a file of advertising copy being kept and monitored at not less than 6 monthly intervals.

 

 

Other Issues

 

Where a company, organisation or person acts or might reasonably be perceived to act on behalf of MAEL, that company, organisation or person will be expected to conduct business in accordance with this Ethics Policy.

 

Dealing with Complaints

 

It will be the normal expectation that complaints will be dealt with in accordance with the grievance policy.  A log of all such complaints will be kept in accordance with that policy.  Where ethical issues form part of a more detailed policy statement, then the procedures in that policy shall be followed.  In other cases grievance policy procedures shall be followed.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

date of last review: 12.03.2016

Appendix to the Ethical Practice Policy

 

The Declaration of Prague

 

Today’s children and young people, male and female, are citizens of Europe and the world.  In the next decades, European children and young people will be shaping and becoming  responsible for their continent and its future. Their beliefs and values, social attitudes and  approach to learning will determine how prepared our “old continent” will be for the  future.

 

The technological possibilities for shaping our future have increased immensely in the last

decades: biotechnology, microelectronics, nano- and information technology are

increasingly determining our daily lives and social environment. We are in the process of

rethinking our relationship with nature and giving it an ecologically-oriented foundation.

Multi-culturalism is a growing social reality which has already started to influence our

societies in Europe.

 

As today’s adults, we will be handing over to our children a world full of new tasks and

problems. At the same time, it is in our hands to prepare children and young people for dealing with this legacy and for shaping their future. With what kind of social values and

attitude toward life will children and young people take over these tasks? To what extent

will their tolerance, intelligence and competence have been developed, when they become

responsible for the future of Europe?

 

Children and young people live in the present and today’s adults should respect that their

lives will be more uncertain but will also hold more opportunities. It is our task to help

children and young people to reach their potential in order to make use of these

opportunities, personally and for society. The risks will not always be possible to foresee or

prevent.

 

Education can decisively influence the development of a child’s or young person’s

personality and living conditions. Therefore the following principles of the Prague

Declaration should form the basis and reference point for all educational actions and

thinking:

 

Children love to learn, not to be taught!

 

1. Each child has the right to learn in an atmosphere of self-initiated activity and freedom

according to his or her stage of development.

 

2. Each child and young person has the right to fulfill his / her full learning potential by

learning autonomously according to his / her phase of development

 

3. Each child and young person has the right to learn holistically with a constant and

consistent interaction between physical and mental activities.

 

4. Facilitating children and young people in their learning must involve respecting their

dignity. Adults are their learning partners.

 

5. Each adult who is involved in education should make a commitment to know and

respect the UN Convention for Children’s Rights.

 

When all of this becomes reality, Europe will be a lively, creative and peaceful continent.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Promulgated 31/10/2004

 

Advertising Policy

 

The UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code) sections 03-06, 08-10 & 20 shall be applied to all advertising.   In outline this means that:

·         Under no circumstances may an advertisement be misleading (including omitting vital information or mitting the identity of the advertiser)

·         If an advert encourages consumers to buy a product or service through a distance-selling mechanism, the writer must seek legal advice to ensure it complies with the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013.

·         Advertisements must not contain anything that is likely to cause serious or widespread offence. Particular care must be taken to avoid causing offence on the grounds of race, religion, gender, sexual orientation, disability or age.

·         Adverts should not feature children without considerable care being taken over privacy issues.  Any such advert must be referred to the MD.

·         No identifiable person may be featured without full and informed consent of that person.

·         Sales promotions must clearly indicate any limitations (e.g. times or localities or qualifying conditions) and the necessary resources identified and sequestered prior to placing the ad.

·         Responders to advertisers must be made aware that taking a qualification cannot guarantee employment or career advancement.

 

Fuller details can be found on https://www.cap.org.uk/Advertising-Codes/~/media/Files/CAP/Codes%20CAP%20pdf/The%20CAP%20Code.ashx

 With specific reference to the advertising of qualifications:

·                                            MAEL will not (and will take all reasonable steps to ensure that any person connected with it does not) make any statement that would be likely to lead users of qualifications which are not accredited to believe that a qualification MAEL makes available is an accredited qualification when it is not an accredited qualification.

·                                            MAEL will not (and will take all reasonable steps to ensure that any person connected with it does not) advertise or promote its qualifications in a manner that is likely to be misleading in any way to users of qualifications.  All advertising copy or publicity material must be submitted to the MD for approval before use, and this shall be part of the teaching centres’ contract.

·                                            MAEL will ensure that any approved use of an accreditor’s or regulator’s logo complies with Logo Requirements and Certificate Requirements which may be published by the authority and revised from time to time.  The CE will check the certificate design conforms to all requirements before the annual submission of results.  He/she will achieve this through identifying the latest requirements and if they have changed producing a list of all requirements (or updating last year’s list) and using that in a table with a note against each as to how it is complied with.  This tabulation will then be shared with the CEO to be checked by him/her. Any issues will be discussed with the CE and resolved.  Any unresolved issues will be referred to the MD for a director’s decision.

With reference to third parties i.e. teaching centres, MAEL expects conformity to this policy on advertising and reserves the right to seek financial redress for any breach thereof.

The title of a qualification must be used consistently in both advertising, internal documentation and any communications with users.  It is also incumbent on the company to ensure that the titles of qualifications which are made available (or proposed) are not misleading to users of the qualifications.  This is part of the MD’s responsibilities.

 

 

 

 

 

 

Document revised 12.03.16