Code of Conduct for Trustees/Trust Associates 2021/2022

The trust’s core values are:

  • An expectation of the highest possible standards of ethical behaviour
  • An appreciation of the importance of localism, partnership and collaboration
  • A determination to being fully inclusive
  • A constant striving for excellence
  • A commitment to the wellbeing of every member of its community of learners, staff and

The trust board has the following core strategic functions: 

Establishing the strategic direction, by:

  • Setting and ensuring clarity of the vision, values, and objectives for the trust and its schools
  • Agreeing the school improvement strategy with priorities and targets
  • Meeting statutory duties

Ensuring accountability, by:

  • Appointing senior and executive leaders
  • Monitoring the educational performance of its schools and their progress towards targets
  • Conducting performance managing of senior and executive leaders 
  • Engaging with stakeholders
  • Contributing to school self-evaluation

Ensuring financial performance, by:

  • Setting the budget
  • Monitoring spending against the budget
  • Ensuring money is well spent and value for money is obtained
  • Ensuring risks to the organisation are managed

The trust board may choose to delegate responsibilities to committees in line with the prevailing scheme of delegation. The trust board may choose to supplement its numbers by appointing trust associates to work alongside trustees on those committees. While trust associates will not have the same responsibilities as trustees they are expected to conduct themselves according to the same code of conduct.

As trustees/trust associates we agree to the following:

Standards of behaviour

  • We – all trustees and trust associates appointed by the board – will at all times expect the highest ethical standards of ourselves and all others engaged in the governance and leadership of the trust and its schools, in line with the Framework for Ethical Leadership in Education (Annex A) which includes the Seven Principles of Public Life (“The Nolan Principles”)
  • We will at all times operate in ways that are consistent with and which help to promote the trust’s values

Role and Responsibilities  

  • We understand the purpose of the board and the role of the trust’s headteachers and Executive Director. 
  • We accept that we have no legal authority to act individually, except when the board has given us delegated authority to do so, and therefore we will only speak on behalf of the trust board when we have been specifically authorised to do so. 
  • We accept collective responsibility for all decisions made by the board or its delegated agents. This means that we will not speak against majority decisions outside the trust board (or committee) meeting.
  • We have a duty to act fairly and without prejudice, and in so far as we have responsibility for staff, we will fulfil all that is expected of a good employer. 
  • We will encourage open governance and will act appropriately. 
  • We will consider carefully how our decisions may affect the community and other schools. 
  • We will always be mindful of our responsibility to maintain and develop the ethos and reputation of the trust and its school. Our actions within the trust/its schools and the local community will reflect this.
  • In making or responding to criticism or complaints affecting the trust and/or its schools we will follow the procedures established by the trust board. 
  • We will actively support and challenge the Executive Director  and headteachers.
  • We will accept and respect the difference in roles between the board and staff, ensuring that we work collectively for the benefit of the organisation.
  • We will respect the role of the headteachers and their responsibility for the day to day management of the school and avoid any actions that might undermine such arrangements.
  • We agree to adhere to the operational rules and policies of the schools within the trust and the procedures of the trust board as set out by the relevant governing documents and law.
  • When formally speaking or writing in our governing role we will ensure our comments reflect current organisational policy even if they might be different to our personal views.
  • When communicating in our private capacity (including on social media) we will be mindful of and strive to uphold the reputation of the organisation.


  • We commit to work collectively to embed a culture of effective succession planning. This will be achieved by identifying successors, nurturing and mentoring talent to ensure smooth transition of leadership roles i.e. chair, vice chair, chairs of committees and link trustee positions. As individuals we will complete an annual evaluation and skills audit to identify strengths or areas for leadership development within the board.
  • We acknowledge that accepting office as a trustee/trust associate involves the commitment of significant amounts of time and energy. 
  • We will each involve ourselves actively in the work of the trust board/its committees, and accept our fair share of responsibilities, including (for trustees -service on committees or) working groups or taking on a lead role in a specific area of governance. 
  • We will commit to attend all meetings and where we cannot attend, explain in advance to the governance professional or the chair why we are unable to.
  • We will get to know the schools within the trust well and respond to opportunities to involve ourselves in school activities.
  • We will undertake a school visit, during the school day, at least once each academic year, with all visits to school arranged in advance with the applicable staff, undertaken within the framework established by the trust board and agreed with the headteacher. 
  • When visiting a school in a personal capacity (ie as a parent or carer), we will maintain our underlying responsibility as a trustee/trust associate.
  • We will consider seriously our individual and collective needs for training and development, and will all undertake to attend the ‘Getting to Grips with Governance’ CPD session within the first 3-6 months of appointment. 
  • To ensure our safeguarding responsibilities are adhered to we will all commit to completing safeguarding training and to read the ‘Keeping Children Safe in Education’ guidance (and each updated edition). We collectively acknowledge the requirement for at least two designated safeguarding link trustees/trust associates to be in place at all times (including one trustee reporting directly to the board). 
  • We acknowledge that if, as individuals we do not comply with training expectations this could lead to possible suspension from the board/its committees.
  • We will commit to refresh relevant training every three years (2 to 3 years in the case of safer recruitment) to keep abreast of current changes in governance legislation. 
  • We accept that in the best interests of open governance, our full names, date of appointment, term of office, roles on the board/committees, attendance records, relevant business and pecuniary interests, category of governance, date of resignation and applicable appointing body will be published on the school website.
  • In the interests of transparency we accept that information relating to trustees and trustee associates sitting on local academy committees will be collected and logged on the DfE’s national database of governors – Get Information about Schools (GIAS).
  • We acknowledge that in accordance with government legislation we will provide the required information and produce the original documentation needed for the submission of an application for an enhanced Disclosure and Barring Service (DBS) check within 21 days of appointment to the board/one of its committees.
  • (For new trustees/trust associates) we acknowledge and agree to note our application form number and register without delay with the Disclosure and Barring Service (DBS) Update Service (free to volunteers) at We acknowledge that by registering to the Update Service an annual DBS check will be electronically renewed, free of charge, in my capacity as a trustee on this Board.


  • We will strive to work as a team in which constructive working relationships are actively promoted. 
  • We will express views openly, courteously and respectfully in all our communications with other trustees/trust associate, the governance professional and school staff both inside and outside of meetings.
  • We will support the chair in their role of ensuring appropriate conduct both at meetings and at all times.
  • We are prepared to answer queries from other trustees/trust associates in relation to delegated functions and take into account any concerns expressed, and we will acknowledge the time, effort and skills that have been committed to the delegated function by those involved.
  • We will seek to develop effective working relationships, in particular: with the Executive Director (trustees): and headteacher, staff and parents, the local authority and other relevant stakeholders within our community (trust associates on local academy committees). 
  • We will acknowledge that as trustees/trust associates we are representatives of our category of governorship, as opposed to representatives for parents or staff and are primarily appointed due to the skills that we bring to the board/committee.

Proceedings of the trust board/committees

  • As a corporate body, we agree to make unanimous decisions by email, if deemed necessary/urgent and such decisions will subsequently be ratified and minuted at the next scheduled meeting.
  • Trustees may participate or vote at meetings by telephone or video conference provided at least 48 hours notice has been given to the governance professional or chair (or as provided for in the trust’s Articles.
  • We agree to follow the Guidance on the Conduct of Meetings (Annex B)
  • We agree to conduct all electronic correspondence within the domain.


  • We will observe complete confidentiality when matters are deemed confidential or where they concern specific members of staff or pupils, both inside or outside school and online.
  • We will exercise the greatest prudence at all times when discussions regarding school business arise outside a trust board or committee meeting (including online). 
  • We will not reveal the details of any trust board or committee vote.
  • We will comply with the Trust Data Protection Guidelines adopted by the trust (Annex C).
  • We will use the Trust domain email account issued to us for all correspondence in relation to Trust business and to access trust papers held in the trust’s Google Drive.

Conflicts of interest

  • We will record any pecuniary or other business interests (including those related to people we are connected with) that we have in connection with the trust’s business (including its committees) in the Register of Business Interests. We will review and declare our interests annually and over the course of each year will immediately declare any new interests as they arise to the governance professional. 
  • We will also declare any interest or conflict of loyalty at the start of any meeting in respect of any agenda item (and in respect of any other matter that may arise during a meeting) and:
    • offer to leave the meeting for the appropriate length of time; and 
    • not take part in any discussion or decision making in relation to that matter.
  • We accept that the Register of Business and trustees’ details will be published on the school website. Any trustee failing to provide information to enable the trust board to fulfil their responsibilities may be in breach of the Code of Conduct and as a result be bringing the trust board into disrepute.
  • We will act in the best interests of the trust and its schools as a whole and not as a representative of any group, even if elected by a particular group  (including staff and parents).

Ceasing to be a trustee or trust associate  

  • We understand that the requirements relating to confidentiality will continue to apply after a trustee or trust associate leaves office.

Breach of this code of conduct

  • If we believe this code has been breached, we will raise this issue with the chair and the chair will investigate; the trust board will only use suspension/removal as a last resort after seeking to resolve any difficulties or disputes in more constructive ways.
  • Should it be the chair that we believe has breached this code, we will raise the issue with another trustee, such as the vice chair, who will investigate.

This Code of Conduct was formally adopted by the trust board of Kingston Educational Trust on 11 October 2021 


Annex A: The Framework for Ethical Leadership in Education 

The Ethical Framework for Educational Leadership is based upon the seven principles of public life (The Nolan Principles). The Committee on Standards in Public Life was established by the then Prime Minister in October 1994, under the Chairmanship of Lord Nolan, to consider standards of conduct in various areas of public life, and to make recommendations.

  1. Selflessness: School and college leaders should act solely in the interest of children and young people.
  2. Integrity: School and college leaders must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. Before acting and taking decisions, they must declare and resolve openly any perceived conflict of interest and relationships.
  3. Objectivity: School and college leaders must act and take decisions impartially and fairly, using the best evidence and without discrimination or bias. Leaders should be dispassionate, exercising judgement and analysis for the good of children and young people.
  4. Accountability: School and college leaders are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
  5. Openness: School and college leaders should expect to act and take decisions in an open and transparent manner. Information should not be withheld from scrutiny unless there are clear and lawful reasons for so doing.
  6. Honesty: School and college leaders should be truthful.
  7. Leadership: School and college leaders should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles, and be willing to challenge poor behaviour wherever it occurs. Leaders include both those who are paid to lead schools and colleges and those who volunteer to govern them.

Schools and colleges serve children and young people and help them grow into fulfilled and valued citizens. As role models for the young, how we behave as leaders is as important as what we do. Leaders should show leadership through the following personal characteristics or virtues:

a. Trust: leaders are trustworthy and reliable

We hold trust on behalf of children and should be beyond reproach. We are honest about our motivations.

b. Wisdom: leaders use experience, knowledge and insight

We use experience, knowledge, insight, understanding and good sense to make sound judgements. We demonstrate restraint and self-awareness, act calmly and rationally, exercise moderation and propriety as we serve our schools and colleges wisely.

c. Kindness: leaders demonstrate respect, generosity of spirit, understanding and good temper

We give difficult messages humanely where conflict is unavoidable.

d. Justice: leaders are fair and work for the good of all children

We work fairly for the good of children from all backgrounds. We seek to enable all young people to lead useful, happy and fulfilling lives.

e. Service: leaders are conscientious and dutiful

We demonstrate humility and self-control, supporting the structures and rules which safeguard quality. Our actions protect high-quality education.

f. Courage: leaders work courageously in the best interests of children and young people

We protect their safety and their right to a broad, effective and creative education. We hold one another to account courageously.

g. Optimism: leaders are positive and encouraging

Despite difficulties and pressures, we are developing excellent education to change the world for the better.


Annex B: Guidance on conduct of meetings


Meetings of the Trust Board and its various committees are the primary means by which the Trust’s governance is enacted. As such these are important and significant events and all participants are expected to engage with them in as professional a manner as possible. It is essential that all trustees/trust associates are clear as to their role and the expectations of them.

The purpose of this guidance is to describe the approach to conducting meetings that has been agreed by the Trust Board and adopted as part of its working practice.

Guiding Principles

  • The role of trustees/trust associates and other participants in meetings is to contribute to the strategic oversight and accountability of the Trust’s operations and to provide challenge and support as appropriate.
  • Trustees/trust associates are expected to approach these activities in a way that may be described as “eyes on, hands off” with regard to the balance between strategic and operational involvement.
  • Trustees/trust associates are expected to be sufficiently prepared for meetings to ensure that they are able to contribute and that those contributions are well-informed and appropriate.
    To aid this:

    • trustees/trust associates are encouraged to attend whatever training (or to seek advice from others) they deem as necessary to develop their knowledge of the topics under discussion;
    • papers should be available one week in advance of the meeting;
    • papers should be prepared in such a way as to minimise the use of acronyms and technical language as far as is possible.
    • Chairs should ensure that all meetings are conducted in such a way as to enable all trustees/trust associates (and other participants) to feel confident to speak up and to contribute. Chairs should seek to draw all participants into discussions.
    • The time available for meetings is constrained and limited. As a consequence, all participants are expected to ensure that the available time is used to the maximum benefit of all.
    • Meetings should always start promptly at the appointed time, regardless of the non-attendance of latecomers, unless there are exceptional reasons not to do so (including quoracy).
    • The Chairs of all meetings should aim to ensure that time-keeping is sufficiently robust to ensure that meetings end by the appointed time.
      To aid this Chairs should:

-aim for as few items on agendas as are necessary, which will also ensure the maximum amount of time for discussion;

 -ensure that agenda items have provisional timings;

 -devote no more time than is essential for considering outstanding actions and reviewing previous meetings;

-prevent the repetition of material that has been circulated in advance, concentrating instead on discussion of it;

-feel able to close a discussion down and suggest that specific points are developed outside of meetings if they feel a real need to  do so;

– ensure that all points for further action are noted by those responsible.

  • Attendance at meetings by staff (and other participants) is sometimes necessary and often helpful. Chairs will decide how this engagement is to be organised to maximise the contribution to the meeting while being mindful of the need not to occupy staff and visitors for longer than is necessary.
  • The draft minutes of the meeting will be circulated by the governance professional to the Chair for checking within 7 days of the meeting.
  • The draft minutes will be checked, amended as necessary and returned to the governance professional by the Chair within 7 days of receipt.
  • The finalised minutes of the meeting will be circulated to all who should receive them by the governance professional within 2 days of receipt from the Chair.
  • Actions arising from the meeting should be followed up by those responsible as soon as possible, with updates on progress expected at the next meeting.

Annex C: Trustee Data Protection Guidelines

The data protection officer (DPO) is:  Zara Gallagher

  • Personal data: is any information relating to an identified, or identifiable person, e.g. name, contact details, email address, attendance and assessment information, financial information.

The definition is extremely wide and includes any references to an identifiable person in emails.

  • Sensitive personal data: is special categories of personal data that require a higher level of protection including information that reveals someone’s ethnic origin, political opinions, religion, sexuality or health. In schools, it also means safeguarding information, whether a child is looked-after, has SEN, or is eligible for the Pupil Premium Grant
  • As the Data Controller, the Trust has a responsibility to manage and safeguard personal data. 



Trustee/Trust Associate Access to Personal Data

  1. Under data protection regulations, personal data should only be shared with those who need that data to perform their roles. Information that is collected and shared should be no wider than that required and held no longer than necessary. 
  2. Whilst schools collect a wealth of personal data to perform its functions, trustees/trust associates should only have access to this data if they need the information to carry out their duties. This means that:
  • Data shared with trustees/trust associates for monitoring purposes must always be anonymised. 
  • Generally, personal data will only be shared with trustees/trust associates in the following limited circumstances, where:
    • they are sitting on a panel to review the head teacher’s decision to exclude a pupil 
    • they are sitting on an Admissions Panel
    • they are sitting on an appeal panel (disciplinary, capability, grievance, pay)
    • a complaint has been escalated to the Trust (in accordance with the complaints procedures)
    • a member of staff or pupil becomes identifiable or is identified during a meeting and this discussion is captured in confidential minutes.

Documents containing personal data must be treated as confidential and held securely.


How Personal Data is Shared with Trustees

    1. Where documents containing personal data need to be shared with trustees/trust associates, these will be made available by sharing them in a confidential folder in Google Drive. Only trustees/trust associates or members of staff who require that information to carry out their duties will be given access to that folder. 
    2. Confidential folders will only be shared with trustees’/trust associates’ trust Google Accounts. These documents must not be downloaded or shared and trustees/trust associates must ensure that any documents that are inadvertently downloaded from confidential folders are deleted from their own private device without delay.
    3. Trustees/trust associates must use a strong password for their trust Google Account and hold this securely.
    4. Where hard copies of papers are prepared for a hearing or meeting, these will be placed in a secure envelope marked ‘Confidential’ and either delivered by hand or sent by registered post. These hard copies should be returned to the governance professional at the end of the hearing or meeting to be shredded. 


Keeping Personal Data secure

    1. Trustees/trust associates must ensure that any hard copy personal data held is stored securely and returned to the governance professional for shredding when no longer required.
    2. When accessing documents containing personal data via Google Drive Trustees/trust associates must: 
  • ensure personal data on a screen cannot be read by unauthorised persons, for example in a public area;
  •  log out of the account when they have finished, if Google Drive is accessed on a shared device or if their private device is not password protected;
  • lock the screen if the device is left unattended whilst logged on to Google Drive;

Private email addresses must not be used to share personal data. If at any time personal data is sent to your personal email address, the email and any downloaded documents should be deleted as soon as possible.


Data Protection Breaches

Personal data that has been lost, stolen or wrongly disclosed, must be immediately reported to the DPO so that steps can be taken to mitigate the impact of the breach. In addition, all breaches are required to be logged and in some cases reported to the Information Commissioner’s Office within 72 hours.

Trustees/trust associates should also speak to the DPO if they have any concerns at all about keeping personal data safe.