Global Code of Conduct

Global Code of Conduct
Introduction
This Study Group Code of Conduct sets out the minimum standards expected of all individuals
who work within or for Study Group. This document and associated policies do not apply to our
students, unless stated otherwise.
These global standards provide the behavioural principles that you must adhere to within your
role. You, your colleagues and your managers are expected to apply and follow these standards
during your time working here, irrespective of location, business, job role or contract type
(employee, casual worker, agency worker).
Some sections have more detailed global policies and/or non-contractual processes, forms or
supplementary information that must also be applied within your geographical region or
business. Where this is the case, these are clearly identified within the relevant section.
Academic policies that relate specifically to the training, supervision and protection of students
within your college or school are not included in here. These will be signposted to you separately
by your academic institution.
This Code of Conduct will be reviewed and refreshed annually as part of our ongoing working
relationship. If a standard is amended during the year, then your Human Resources team will
notify you, and the most current version will continue to be linked from the regional People
Policy pages of myStudyGroup.com
It is imperative that you raise any concerns regarding our expectations of you at the earliest
opportunity, as not abiding by the minimum standards may result in disciplinary action.
Jeanette Gooding
Global HR Director
Study Group
Working for StudyGroup
Conflicting Information
With around 3,000 employees and a huge international reach, you will find on occasion that the
global principles outlined here conflict with other advice that you have been provided with. So
which standard are you expected to follow?
1. Firstly, the minimum standards expected by Study Group of all individuals are outlined
here, so this the Global Code of Conduct - is always your starting point.
2. Where your employment contract, regulatory requirements, or country/state legislation
say that you must do something different, then it is more important that you follow the
law. Always do what you are legally required to.
3. In all other cases, you should follow any local business-branded policies or procedures, as
these should supplement the minimum Study Group standards and legislative
requirements above. These might apply to all staff at your location or be specific to
either academic or non-academic staff. Your local documentation may be branded
differently.
You are expected to read, understand and comply with the terms of this Code of Conduct.
However this Code of Conduct does not form part of your contract of employment with Study
Group and/or its subsidiaries.
If you identify an inconsistency or are unclear as to what is expected of you, then contact the
Regional Owner shown within these pages or speak to your Human Resources team.
Version Control
Version
1.0
Changes since Last Version

Date Introduced
1 June 2015
Next Review Date
December 2015
in preparation for 2016 revision
Earlier Versions
Effective Date: 1 June 2015
1.0
Page 2 of 26
Contents
Alcohol and Drugs ........................................................................................................................................... 4
Attendance...................................................................................................................................................... 5
Bribery and Corruption ................................................................................................................................... 6
Bullying and Harassment ................................................................................................................................ 7
Child / Student Protection .............................................................................................................................. 8
Confidentiality ................................................................................................................................................. 9
Conflicts of Interest - Working Elsewhere .................................................................................................... 10
Corporate Social Responsibility - Positively contributing to communities and the environment ............... 11
Data Protection and Privacy ......................................................................................................................... 12
Delegation of Authority - who can authorise expenditure .......................................................................... 13
Dress Code .................................................................................................................................................... 14
Employee Concerns - Grievance, Whistleblowing ........................................................................................ 15
Employer Concerns - Misconduct, Gross Misconduct .................................................................................. 16
Equal Opportunities ...................................................................................................................................... 17
Health & Safety ............................................................................................................................................. 18
Intellectual Property - who owns the outputs that you create while working here ................................... 19
Performance Management ........................................................................................................................... 20
Personal Conduct .......................................................................................................................................... 21
Rights to Search ............................................................................................................................................ 22
Smoke Free Workplace ................................................................................................................................. 23
Social Media .................................................................................................................................................. 24
Travel and Expenses...................................................................................................................................... 25
Use of Technology......................................................................................................................................... 26
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Alcohol and Drugs

It is imperative for the health, safety and welfare of colleagues and students, and the companys
professional reputation, that an individuals judgement, work performance or behaviour at work is not
affected by the use of either alcohol, prescribed medication or illicit drugs.
As a responsible company, Study Group will provide encouragement when appropriate to an individual
who is actively addressing an underlying or long-term issue.
A small amount of alcohol may be consumed during recognised social occasions where this would not
cause offence to colleagues, clients or suppliers, and where individuals will not be driving or using
hazardous equipment that day.
Where there is cause for concern that an individual is under the influence of alcohol or drugs, they will
not be permitted to remain on work premises, and may be subject to disciplinary action.
Study Group may initiate either drug or alcohol screening or search an individual or an individuals
personal property at work, in order to monitor compliance with this policy. Should an employee refuse to
consent to drug or alcohol testing (following a request from Study Group), Study Group may initiate
disciplinary action on the same basis as if an employee had tested positive for alcohol or drug use.
Any individual found to be in possession or believed to be manufacturing, offering or selling illicit drugs
will be immediately suspended and the appropriate authorities, e.g. the Police, notified.
Individuals should disclose in confidence to Human Resources any drug-related criminal conviction or
violation that occurs outside of the workplace.
Global Policy
No Global Policy above standard applies
Global Policy Owner
N/A
_____________________________________________________________________
Regional Policy Owner
Human Resources Director
Australia and New Zealand
Drugs and Alcohol Policy
USA and Canada
Drug and Alcohol Policy
United Kingdom and Europe
No Regional Policy
Rest of World
No Regional Policy
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Attendance
Punctuality and managing attendance are essential to the efficient running and reputation of Study
Group. Standard working hours differ dependent upon local legislation and your location. You may be
required to attend meetings and training sessions during your contracted hours, either at your normal
place of work or within a reasonable travelling distance. We provide a number of options for you to take
paid and unpaid time away from work, for example annual leave, rest breaks, public duties, family
friendly leave. You are expected to liaise with the relevant manager at your location to schedule and
agree time away from the workplace.
Study Group provides a holiday allowance that matches or exceeds the legal minimum. Leave requests
cannot always be granted. Therefore, you are advised to give as much advance notice as possible, and to
ensure that you have managerial approval for your proposed leave dates, prior to booking any travel
arrangements. You must always take your legal minimum holiday allowance within the current holiday
year. In addition, you are encouraged to use the remainder of your annual allowance before the holiday
year concludes, as carry over arrangements cannot be guaranteed across all locations, other than in those
situations where you have been unable to take your leave due to business requirements.
On occasions where you cannot schedule time away from work, due to unexpected illness, accident or
circumstance, you must telephone the relevant manager at your location - or another manager where
they are unavailable - before you are due to start work. It is your responsibility to keep them informed of
your progress, together with your anticipated date of return. Irrespective of whether your leave is paid
or unpaid, you are expected to provide medical supporting evidence where expected or requested to do
so, and for the company to maintain reasonable contact directly with you. If there is no obvious leave
option available to you, the company may consider written requests for unpaid leave on a case by case
basis.
Where you are not bound by operational or legal requirements, you may exercise your discretion as to
when you may take your rest breaks. You cannot accumulate or carry over rest breaks from one day to
the next, and should not utilise them either at the start or end of your working day.
If you choose to work beyond your standard hours, in order to complete a particular piece of work, this
should be mutually pre-agreed with your manager. Unless you are specifically covered by a paid
overtime agreement, you may agree with your manager to take the same amount of time additionally
worked, as paid time off in lieu. This must occur within a short time of the additional hours being
worked. Managers are generally excluded from this provision as a reflection of their seniority and
autonomy in how to organise their work.
Global Policy
No Global Policy above standard applies
Global Policy Owner
N/A
_____________________________________________________________________

USA and Canada
Rest of World
Conduct Policy
Attendance Policy
Absence Policy
No Regional Policy
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Bribery and Corruption

As an acknowledged leader in international education, Study Group recognises its long-standing ethical
and regulatory responsibilities to act in accordance with applicable anti-bribery and anticorruption laws
and regulations in all our global locations in which we have a presence. Study Group is committed to a
zero tolerance policy and will not tolerate any acts, attempted acts, or assistance with any form of
bribery or corruption whether direct or indirect.
The Anti-Bribery and Anti-Corruption Policy provides clear guidance to Study Group Representatives, and
all other stakeholders with whom Study Group has a relationship, on Study Groups anti-bribery and anticorruption values and commitment to upholding these values. The Anti-Bribery and Anti-Corruption
Policy is part of Study Groups wider commitment to navigate our global business ethically, responsibly
and with moral integrity.
Global Policy
Anti-Bribery and Anti-Corruption Policy
Global Policy Owner
General Counsel
_____________________________________________________________________
Managing Director
No Regional policy
North America
No Regional policy
No Regional policy
Rest of World
No Regional policy
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Bullying and Harassment

Study Group is committed to providing a professional working environment, in which everyone is treated,
and treats others, with dignity and respect. Inappropriate behaviour will not be tolerated irrespective of
where it occurs, for example in the workplace, on business trips, work-related events or during social
functions.
You are asked to avoid creating or encouraging situations that could constitute, or might lead to a perception
of offensive, unwelcome or inappropriate activity. Conduct is unacceptable if a recipient finds behaviour
unwanted or offensive, causes them to feel threatened, humiliated, bullied or harassed, interferes with their
performance, undermines their job security, or creates a threatening or intimidating environment.
The terms bullying and harassment are commonly grouped together, but in practice are two different
things.
Harassment is generally unacceptable conduct which is connected to sex, sexual orientation, marital status,
age, race, colour, nationality, nationality, ethnic origin, religion, belief, or disability.
Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can
make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean
the instigator is in a position of authority, but can include personal strength or the power to coerce through
fear or intimidation. Bullying can take the form of physical, verbal and non-verbal conduct such as physical or
psychological threats, overbearing and intimidating levels of supervision or inappropriate derogatory
remarks about someone's performance. Reasonable management instructions and constructive review of an
individuals performance or behaviour do not amount to bullying.
We encourage anyone who experiences bullying or harassment to attempt to address it informally with the
individual concerned if you feel able to do so. If that is inappropriate or dialogue does not resolve the
problem, then you must report it to your Human Resources team in the first instance. You can be assured
that it will be treated as a serious matter and promptly investigated.
Global Policy
No Global Policy - above standard applies
Global Policy Owner
N/A
_____________________________________________________________________
Anti-Discrimination and Harassment

Anti-Bullying Policy
Grievance Policy
USA and Canada
Discrimination and Harassment Policy
Anti-Bullying and Harassment Policy
Rest of World
No Regional Policy
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Child / Student Protection

As a leading for profit education provider for international students, the safeguarding and welfare of all
our students is of paramount importance. We owe a higher duty of care to our students who are aged
under 18.
Each Region has its own policies and procedures for identifying, managing and mitigating risk of child
protection issues and concerns. All staff are expected to be aware of, and fully understand, the policies
and procedures for their Region and act in accordance with them at all times.
All policies and procedures will reflect our commitment to;
Provide a safe environment for all our students,

Swiftly and efficiently identify and manage cases where students are at risk, or have unmet
welfare needs,
Promote the importance of child protection, safeguarding and welfare across all activities; and
Regularly evaluate our approach and practices with regards to child protection, safeguarding and
welfare, and make any improvements needed.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Operations Director
Child Protection Policy
USA and Canada
No Regional Policy
Child Protection Policy
Rest of World
No Regional Policy
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Confidentiality
In the course of your work, you will receive privileged and confidential information which must not be
shared with third parties other than where required by your role, either during or after your time working
at Study Group, without explicit prior written permission from a senior manager at Study Group.
Study Group has gone to great expense and effort to develop our extensive range of business practice
and information. This includes but is not limited to documents and knowledge such as customer and
contact lists, marketing plans, our methods of conducting business, submission and proposal procedures,
inventions, designs, computer programs, patents, copyrights, procedures, manuals, confidential reports.
The company considers and treats our information and materials as trade secrets. This includes
materials that you have developed whilst working at Study Group. Trade secrets are a valuable, special
and unique asset of our business, which is essential to the continued success of our schools and offices.
Any improper personal use, retention, disclosure and/or transfer of confidential information or trade
secrets constitutes unacceptable behaviour, even where it is not apparent that an individual has
personally gained by such action. Any individual who is believed to be engaging in or has engaged in such
practice will be subject to immediate and appropriate action, including termination and/or legal action.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Conduct Policy
USA and Canada
Confidentiality Policy
Refer to Contract of Employment
Rest of World
No Regional Policy
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Conflicts of Interest
- Working Elsewhere
Study Group recognises that individuals may be engaged in work-related activities outside of your
employment. You must inform your manager of any potential or actual conflicts of interest, in order that
we are aware of and can manage the risks in conjunction with you.
You must not supplement and/or engage in competition with Study Group activities, for example by
providing additional classes to our students, without explicit prior written permission from and ongoing
review by a senior manager at Study Group.
Even where activities are unrelated to our business, we still retain legal obligations towards you, and you
to us. It is immaterial as to whether you are acting in a paid or unpaid capacity.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Conduct Policy
USA and Canada
No Regional Policy
Rest of World
No Regional Policy
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Corporate Social Responsibility

- Positively contributing to communities and the environment
Study Group prepares students for life in a global society and success in a global economy. Due to our
extensive international network, we are privileged to play a pivotal role within the communities we serve.
Whilst financial factors, company size, business strategy, management, brand quality, corporate image
and reputation are all intrinsic elements of our success, this is balanced by our aligning corporate values
with wider ethical and societal considerations.
As an organisation operating in communities around the world, Study Group recognises the global
disparity of educational opportunities and seeks to make a difference by funding the construction of
schools in disadvantaged communities. Our vision is to provide a long-term, sustainable commitment to
educational projects within developing regions through our Building Futures programme.
We also aim to behave responsibly in regards to our impact on the environment, business ethics and
employment practices. We can only accomplish this if consideration for these objectives is integrated
into our decision making. In your role with Study Group, you may be asked to participate in key decisions,
and ensure that we adhere to, or exceed, international and local minimum standards.
Everyone has a part to play in managing our impact, however large or small, whether it is voluntarily
contributing to Building Futures, ensuring safe working practices, sourcing ethical products or
minimising the consumption of natural resources and energy.
Global Policy
Global Policy Owner
Building Futures
Corporate Human Resources Director
_____________________________________________________________________
No Regional Policy
USA and Canada
No Regional Policy
No Regional Policy
Rest of World
No Regional Policy
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Data Protection and Privacy

Personal data held by Study Group in relation to your employment is treated as confidential company
information. It will be obtained and processed fairly, lawfully and confidentially stored. Records will be
accurate, proportionate to the purpose that they are being used for, not held longer than necessary and
may only be disclosed to third parties in appropriate circumstances, for example in order to process
payroll or comply with legislation.
You retain responsibility for providing Study Group with accurate and current information regarding your
personal circumstances where these are relevant to the employment relationship.
If you have access to records relating to colleagues, students or agents as part of your role, you must take
all reasonable care to protect these from unauthorised access or disclosure.
If you manage staff, your responsibilities include creating, reviewing and protecting confidential
information about others.
Global Policy
Global Policy Owner

N/A
_____________________________________________________________________
Privacy Policy and Use of Technology Policy
USA and Canada
No Regional Policy
Data Protection Policy
Rest of World
No Regional Policy
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Delegation of Authority
- who can authorise expenditure
Study Group needs to protect its assets and maintain appropriate financial controls, in order to run our
business effectively and ensure cohesion and consistency to our strategic direction.
The company has clearly defined expectations around who can enter into binding business commitments.
Authority for entering into contracts or agreements with third parties is delegated to certain functions
and management roles.
Individuals who are not Study Group employees, for example agency workers, consultants and
contractors, are not allowed to commit any funds or approve expenditure on behalf of Study Group.
Detailed guidance is provided for both managers and employees as to the levels of expenditure that are
allowed, which roles can incur items of expenditure, and who can approve expenditure. Employees must
not make any oral or written commitments with a third party, without the required level of approval.
Those individuals who have authority to approve expenditure are expected to exercise good business
judgment. Approval must be in line with Study Groups strategies, procedures and budgets. Individuals
may only approve expenditure within their function, area of expertise or cost centre.
There must always be appropriate supporting documentation before any commitment is entered into,
and records maintained. Your finance team will only process transactions that comply with the terms
outlined within the relevant policy.
Global Policy
Matters Reserved for the Board

Delegation of Authority Corporate Policy
Global Policy Owner
Chief Financial Officer
_____________________________________________________________________
Finance Director
Delegation of Authority Divisional Policy
North America
Rest of World
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Dress Code
It is important to Study Group that the professionalism and trust placed in our staff and colleagues is
always held in high regard by others. Gaining respect is highly influenced by both non-verbal cues and
what we say.
Our appearance and how we present ourselves is important, as this can build, or undermine, the
perception of you and of us as an organisation.
Not all of us directly interact with students. However, it is still important that both academics and nonacademic colleagues create a positive impression, and that we mirror the expectations that will be placed
on our students when they progress into the working environment.
If you are provided with a uniform, you are expected to wear this and to keep it clean.
As we work alongside younger people, we are not mandating that staff should be dressed formally. Nor
would it always be appropriate. For instance, if you are an activities organiser, then you are not going to
be dressed in the same way as a sales agent.
Whatever you wear, we ask that you always maintain a tidy appearance, and to respect the following
guidelines:
No sports or beach wear, unless appropriate to your role

No humorous/political/advertising logos
All non-ear piercings to be covered up during work hours
No clothing that is too revealing, suggestive or tight fitting
Global Policy
Global Policy Owner
N/A
_______________________________________________________________________
Dress Code Policy
USA and Canada
Dress Code Policy
No Regional Policy
Rest of World
No Regional Policy
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Employee Concerns
- Grievance, Whistleblowing
Our aim is to provide a positive and productive working environment in which constructive dialogue and
suggestions are welcomed and support always given. We realise however that there might be occasions
when you, your manager or a colleague become dissatisfied with a particular course of action, and you
require a structured and safe mechanism for dealing with these concerns, without fear of reprisal for
doing so.
Do not hesitate to raise genuine concerns, even if later these are determined to be unfounded. We
always encourage you to attempt resolution informally first, by engaging in dialogue either with the
individual concerned or your manager. Where this is inappropriate or does not resolve an issue, then the
company provides structured procedures for you to follow.
The company will engage with you, and resolve matters at what it considers to be the most appropriate
level and as promptly and consistently as business constraints allow.
Where, following due consideration, it is decided that the concerns were raised maliciously or that the
complaints are frivolous or vexatious, the relevant employee may be subject to disciplinary action, up to
and including termination of employment.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Grievance Policy
USA and Canada
Whistle-blowing Policy
UK and Rest of World Grievance Process and

Whistleblowing Process
Rest of World
UK and Rest of World Grievance Process and

Whistleblowing Process
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Employer Concerns
- Misconduct, Gross Misconduct
We hope that our employment relationship will be mutually beneficial. However, we recognise that there
may be occasions when you do not follow the contractual or behavioural standards that are expected of
you. If this occurs, then it is important that we follow a structured and fair process for warning you that
your conduct is not acceptable, and that the employment relationship is in jeopardy.
Firstly, we provide you with the standards that are expected of you, beginning with this Global Code of
Conduct. Where principles are not adhered to or misconduct occurs, this is treated and resolved by the
company applying the disciplinary process.
Whilst not an exhaustive nor exclusive list, examples of unacceptable behaviour known as misconduct
- that may result in a warning include:
unauthorised absence from work

failure to wear appropriate protective clothing or uniform where supplied
poor timekeeping
breach of a reasonable company or management instruction
improper use of equipment
unprofessional behaviour when talking to or working with colleagues or students
behaviour inconsistent with your duty to loyally and properly carry out your role
More serious breaches are known as Gross Misconduct and could result in disciplinary action resulting in
termination of your employment. Examples include but are not limited to:
any action or behaviour which is likely to damage the reputation of the company
theft, fraud or dishonesty (including providing false or misleading information)
fighting or assault
consumption or dealing in drugs
causing financial loss to the company
serious breaches of company standards
knowingly putting others health and safety at risk
disclosing confidential information
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Conduct Policy
USA and Canada
Corrective Discipline Policy
UK and Rest of World Disciplinary Process
Rest of World
UK and Rest of World Disciplinary Process
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Page 16 of 26
Equal Opportunities
Study Group promotes equal opportunity and the avoidance of discrimination, by treating individuals
equally and with fairness at all times when making employment decisions.
We want you to be able to fulfil your potential and build positive working relationships within a
flourishing and dynamic environment, in which your views are welcomed and the diversity of our staff
and student communities are a cause for celebration.
We will achieve this by always making objective decisions based on merit, through ensuring that any
unjustified barriers are removed, and by monitoring our progress.
We are committed to seeking continual improvement, in line with compliance to local legislation, in order
to prevent discrimination in the workplace. All of us hold a responsibility, irrespective of our role, to
ensure that we adopt fair, inclusive and consistent practices throughout the organisation, and to report
any deviation from this.
With your help, we can remove disadvantages where these apply, so that you can fully play your part
within our vibrant organisation. It does not matter to us how old you are, whether you have a physical or
mental disability, are single, married, with a partner, part-time, full-time, what your gender is, whether
you have parental responsibility, what nationality, religion, or sexual orientation you are. What you
positively contribute and how you perform your role on a daily basis are what matter to us.
In order to ensure that everyone can fully maximise their contribution, let Human Resources and/or your
manager know if you need support, or we should be made aware of something that is important to you.
Global Policy
Global Policy Owner
N/A
________________________________________________________________________
Equal Employment Opportunity Policy
USA and Canada
Equal Employment Opportunity Policy
Equality and Diversity Policy
Rest of World
No Regional Policy
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Health & Safety

Study Group will strive to provide, so far as is reasonably practicable, a safe and healthy working and
studying environment for all employees, students and others including those at special risk, according to
its responsibilities under local legislation from time to time.
It is Study Group's policy to take all reasonable steps to:
Provide and maintain safe and healthy working and studying conditions.
Provide safe plant/equipment and safe systems of work for all employees and, where applicable,
students
Ensure the competence of all employees to do their work and provide relevant information,
instruction and supervision for all employees and, where applicable, students
Adequately control health and safety risks arising from work activities
Collect and disseminate up-to-date relevant information on health and safety matters.
Protect the health and safety of others who might be affected by work activities including
students, visitors, contractors and members of the public.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Named individual per region / Operations Director
Health, Safety & Wellbeing
USA and Canada
Health & Safety Policy
UK Health & Safety Huddle
Rest of World
No Regional Policy
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Intellectual Property
- who owns the outputs that you create while working here
Your appointment is intrinsically linked to the skills, knowledge, experience and capabilities that you can
bring to the organisation, and hence the value that you can provide and add within your role.
You have a special duty to further Study Groups interests in this regard. Therefore, anything that you
design or develop within the course of your employment becomes and remains the property of Study
Group and/or its subsidiaries.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
No Regional Policy
USA and Canada
No Regional Policy
Rest of World
No Regional Policy
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Performance Management
Study Group is committed to fostering a work environment that maximises individual and business
performance. In order to achieve this, it is important that you are clear as to our performance and
behavioural expectations, you understand where your role and contribution fit into the wider
organisational and team goals, you work towards clear objectives, and you participate in the regular
receiving and giving of feedback and developmental support.
When you first work with us, there is an initial settling in period, during which both you and we assess
whether we are mutually suited and compatible. We will help you understand what is expected from
you in your particular role, set some preliminary goals and encourage two way dialogue.
Irrespective of whether you have just joined or have been here many years, everyone should receive
regular, honest feedback on what they are doing and how they are doing it. A formal performance
appraisal is completed every twelve months, in order to ensure that there is a structured review of
personal reflection and growth, before mutually agreeing the next set of goals, and identifying any
individual or collective training requirements.
These factors apply just as equally to your manager too. You should feel comfortable in asking for
support or suggesting what they can do differently, in order to increase your levels of job satisfaction and
performance.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Regional Owner
Corrective Performance Management
USA and Canada
Performance Management
No Regional Policy
Rest of World
No Regional Policy
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Personal Conduct
Workspace Management
A kitchen is provided for the use of the staff. In the interests of everyone's health and safety and a pleasant
working environment you are required to keep this, and your general work area, clean and tidy. Before
leaving for the evening, make sure your desktop is clear of documents, dirty crockery, and generally left in a
tidy state. This allows the cleaning staff to clean your desk, ensures that confidential items have been safely
secured, lessens the chance of losing or misplacing work, and enables others to work at your desk if you are
away. Please put all litter and recyclable materials into the appropriate bins and ensure any confidential
waste is disposed of securely.
Music
As much of our business takes place over the telephone and in shared office spaces, we ask that you
refrain from playing music or radios in the workplace, other than where required for teaching purposes.
As persistent music and unnecessary commentary can be distracting and disturbing to others even at low
volume, personal headsets and all personal music devices should not be used during working hours,
without permission from your manager.
Personal Property
Most of our facilities have public access and we often have open plan offices and workspaces. We advise
you not to bring valuable personal possessions or large amounts of cash to work, as you do so at your
own risk. You are responsible for the security of your personal possessions, and we cannot take
responsibility for the replacement of lost or stolen personal property.
Working Together
A sense of teamwork and camaraderie are key ingredients to helping Study Group to succeed, and for you
to enjoy working here. Swearing within the working environment is unacceptable. If you have a
disagreement with other individual(s), then Study Group expects a professional approach to be adopted.
Any direct or indirect act or threat of verbal or physical violence against any member of staff, customer or
another person at work is likely to result in disciplinary action up to and including dismissal, and could
result in criminal prosecution.
Relations with the local community
Study Group believes in maintaining good relations with the local community and you are requested to
comply with this, for example by handling any queries from the general public quickly and courteously;
treating the companys neighbours and their property with respect; not parking your car to cause
obstruction or nuisance near work; not throwing litter in the street or in the vicinity of the companys
premises; not smoking in front of other organisations or private individuals doors; and, leaving work
quietly, particularly after normal working hours.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
Business Conduct
USA and Canada
No Regional Policy
No Regional Policy
Rest of World
No Regional Policy
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Page 21 of 26
Rights to Search
A key factor in the relationship between you and Study Group depends upon a high degree of mutual
trust and confidence. We collectively rely on each other to be honest and respectful and not to conduct
ourselves in a manner calculated to destroy this fundamental principle. We expect you to serve Study
Group loyally and in good faith by not:
misusing company property or resources

soliciting customers or clients
setting up in direct competition with us
disrupting our business
damaging our company reputation
risking the health and safety of students or colleagues
We monitor what happens in our business via a variety of methods such as reviewing the usage of IT
equipment and communications, CCTV recording, implementing security measures, etc. to ensure that
our business and the personal interests of your colleagues and students are protected. By working here,
you accept that if there is justifiable cause, then Study Group may use appropriate search methods.
Other than for routine searches, if there is justifiable concern regarding your behaviour, then a physical
search of you/r personal effects may be conducted in line with the following principles:
Your consent would be requested, and the reason for the search explained
(unless you are non-contactable and it is felt that the search of your personal effects cannot wait
until your anticipated return, in which case you will be informed that a search has taken place at
the earliest opportunity)
The search would be conducted by a member of security or a manager
An available, mutually-acceptable witness should be present
The search would be carried out with care and respect for your belongings
Physical contact would be minimised and carried out by a member of the same sex
The search will be conducted as privately as possible in the circumstances
The results will be confidentially logged
The results will only be shared by you and us on a need to know basis
Should you refuse a search request, then you should state precisely why you are refusing, as Study Group
will draw its own conclusion from your refusal. Study Group always reserves the right to call in an
appropriate external authority such as the Police where there is suspicion of, or a matter is considered to
be, unlawful.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
No Regional Policy
USA and Canada
No Regional Policy
No Regional Policy
Rest of World
No Regional Policy
1.0
Page 22 of 26
Smoke Free Workplace

Study Group operates a smoke-free environment. This includes but is not limited to all reception areas,
offices, staff rooms and restaurants, and applies equally to electronic cigarettes, otherwise known as ecigarettes.
You may however smoke in the designated smoking area for your location.
We do not provide additional breaks for individuals who smoke. Therefore, you should endeavour to
smoke during designated rest breaks. If you smoke outside of a designated rest break with the
acceptance of your manager, you must not exceed your maximum daily break allowance, so for example
you would need to reduce your lunch break accordingly.
Global Policy
Global Policy Owner
N/A
_____________________________________________________________________
No Regional Policy
USA and Canada
No Regional Policy
No Regional Policy
Rest of World
No Regional Policy
1.0
Page 23 of 26
Social Media
Social media is the social interaction in which individuals create, share or exchange information, ideas,
and pictures or videos within virtual communities and networks. This includes all forms of social media,
including Facebook, LinkedIn, Twitter, Google+, Wikipedia, Whisper, Instagram, Vine, Tumblr and all other
social networking sites, internet postings and blogs. It applies to use of social media for business
purposes as well as personal use that may affect our business in any way.
We encourage use of social media where it is used appropriately, such as building your professional
profile, contributing to positive engagement with colleagues, and following our organisational posts. You
are permitted to add limited business contacts to your personal social networking accounts, on the strict
condition that you or a third party do not use or share this information to compete with Study Group
either now or in the future, or to solicit our contacts. From a child and student protection perspective,
you must not socially connect with current students, unless you have authorisation to do so through
channels that specifically exist and are permitted within your business.
Generally, social media is permitted provided such use is lawful, does not occur when you are working unless it is a fundamental requirement of your role, does not negatively impact upon you or others
performance, or damage the reputation, image, performance, security or availability of Study Group or its
IT systems. The use of social media must not cause any additional cost to Study Group.
You must avoid making any social media or media communications that could directly or indirectly
damage our business interests or reputation. You must not use social media to defame or criticise us, our
staff or any third party; to harass, bully or unlawfully discriminate against individuals or organisations; to
make false or misleading statements; or to impersonate colleagues or third parties. You must not express
opinions on our behalf via social media, unless expressly authorised to do so. Nor must you post
comments about sensitive business-related topics, such as our performance, or do anything to jeopardise
our trade secrets, confidential information or intellectual property. You must not include our logos or
other trademarks in any social media posting or in your profile. You may not set up social media profiles
or pages on behalf of, or designed to represent, the company, unless authorised by your Regional Owner.
You should make it clear in postings, or in your personal profile, that you are speaking on your own
behalf. Always write in the first person and use a personal email address. Be respectful to others when
making any statement and be aware that you are personally responsible for any harm caused.
If you disclose your link with us on your profile or in postings, you must state that your views do not
represent those of Study Group, unless you are authorised to speak on our behalf. You should also
ensure that your profile and any content you post are consistent with the professional image we would
wish to present to clients and colleagues. If you are uncertain or concerned about the appropriateness of
any statement or posting, refrain from posting it until it has been approved. You may be required to
remove any social media content that we consider to be inappropriate.
Global Policy
Global Policy Owner
Social Media Manager, UK & Europe
_____________________________________________________________________
Regional Owner
Marketing Team (Australia & New Zealand, USA & Canada)
Social Media Manager (UK & Europe, Rest of World)
Social Media Policy
USA and Canada
No Regional Policy
No Regional Policy
Rest of World
No Regional Policy
1.0
Page 24 of 26
Travel and Expenses

Expenses, travel and associated expenditure represent a significant cost to the organisation. It is
important therefore that you have a clear and consistent understanding of which expenses are
reimbursed and how and when to claim them.
Detailed guidance is provided, in order that you can familiarise yourself with what is acceptable
expenditure and the expense procedures that you must follow. The policy covers a diverse range of
topics including international and domestic travel, meals and entertainment, off-site meetings,
communication costs, professional membership fees and subscriptions, special personal occasions (e.g.
retirement), company social events, charitable donations, and treatment of rewards and recognition.
It also provides you with which expenses are not reimbursable, for example non-employee expenses or
when to contact Human Resources on employment related matters such as taxation incurred by your
employment in another country, relocation expenses or remote working.
Expenses must always be legitimate and business-related, cost effective, and compliant with local tax
requirements. They must be approved by a manager, who is responsible for ensuring internal
compliance, and for verifying the legitimacy and accuracy of charges.
Overstating incurred expenditure or making false claims will be viewed seriously as an attempt to defraud
the company. By approving an expense, the approving manager will be held accountable, in the same
way as the individual who submitted the fraudulent expense claim.
Expense reports will be subject to audit. Where a genuine error has occurred, individuals will be required
to repay any monies incorrectly reimbursed to them.
Global Policy
Global Travel and Expenses Policy
Global Policy Owner
Chief Financial Officer
_____________________________________________________________________
Finance Director
Any additional information may be found in the Australia and

New Zealand pages
North America
No Regional Policy
No Regional Policy
Rest of World
Any additional information may be found in the Rest of World pages
1.0
Page 25 of 26
Use of Technology
You are expected to adhere to the separate, more detailed global policy, which deals with the provision
of technology resources by Study Group and the associated responsibility of authorised users when
accessing Study Group business tools and information. These resources include, but are not limited to,
the Study Group network, computer systems and software, access to the Internet, electronic mail,
telephony and related services.
The policy is based on the following mandatory principles:
The technology resources of Study Group are provided to support the teaching, research,
administrative, marketing and other business activities of Study Group
Authorised users are granted access to valuable Study Group resources, sensitive data and to
external networks on the basis that their use of IT resources shall be responsible, ethical and
lawful at all times
Authorised users are required to observe Study Group policy, and all related local laws which
may apply
Data and information relating to persons (specifically, but not limited to potential, future,
current or past students, staff or agents) and other confidential matters acquired for business
purposes shall be protected
Personally identifiable information shall be handled in accordance with all applicable privacy
legislation and/or principles
Study Group business information shall be protected from unauthorised and/or accidental
disclosure; and
Study Group technology resources must not under any circumstances be used to harass,
humiliate or intimidate others or to offend or vilify others on the basis of their race, gender, or
any other attribute prescribed under anti-discrimination legislation.
Should you be away from work, your manager has the right to request and receive access to your
business email account and documents.
Global Policy
Use of Technology Policy
Global Policy Owner

Global IT Operations Director
_____________________________________________________________________
IT Director
Use of Technology
USA and Canada
Use of Technology Policy
IT Acceptable Use
Rest of World
No Regional Policy
End
1.0
Page 26 of 26

Global Code of Conduct

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Global Code of Conduct

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Global Code of Conduct

Working for StudyGroup