1.0 About our Code of Conduct 

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

The purpose of the Code of Conduct is to:

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

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

John C Schroder
Group Managing Director and Chief Executive Officer 

2.0 Our Values 

In 2023, we refreshed our Values to better reflect who we are and what we stand for at CLV.

Our Values are designed to express how we do things around here, to guide our thinking and influence our actions and decisions, both individually and as part of our teams.

These Values help us demonstrate what kind of place CLV is, and how the way each of us behaves, contributes to our culture. We believe these Values are already evident across the business, in our teams and in our villages, but we want your help to ensure that we continue to bring them to life every day, with whoever you interact with.  

Care: We care about what we do in our role in our communities

Accountability: We are each responsible for our own words, actions, decisions and results. 

Integrity: We are open, honest and do the right thing 

Teamwork: We work together collaboratively and respect everyone 

Our Values and Code of Conduct Guidelines are aligned as follows: 

Care 

  • We maintain a safe and healthy workplace
  • We minimize our environmental footprint

Accountability 

  • We safeguard our company assets
  • We safeguard CLV’s reputation 

Integrity 

  • We conduct business honestly and ethically
  • We act in the best interests of CLV

Teamwork 

  • We celebrate diversity and inclusion
  • We respect all and treat everyone equitably 

3.0 Principles of Our Code 

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

A | Making good decisions

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

B | Conduct business legally and ethically

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

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

Please refer to your Group and regional policy/reference library for the most up-to-date policies and procedures or reach out to the People Team if you have any questions. CLV Group has mandatory compliance training in place on CLV’s Online Learning Academy.

This training will help you understand Group policies and procedures and apply them in your everyday work. Each region may have additional mandatory training on other platforms, that must be completed within established timeframes.

D | Ask questions

The Code of Conduct is just the starting point. It establishes basic expectations for how we are to conduct ourselves in the workplace; but it does not have the answer to every question or every situation. If you are unsure of which policy to follow, seek guidance on policies to be used, and actions that may be appropriate. If you are unsure at any stage, or if you believe there may be a conflict between a company policy and local legislation, ask the People Team.

E | Speak up
We are all trying to get things right together. Speaking up means asking questions so we can ensure we are living up to the high standards that we set at CLV.

CLV is committed to listening to all concerns raised. Speaking up is encouraged and appreciated, it is an obligation we all have to each other. If you see or suspect a contravention of the Code of Conduct, say something. Every employee is accountable for upholding the Code of Conduct. You can also make a report personally by proxy or anonymously on the CLV Integrity/Speak-Out Helpline.

We all have a responsibility to report improper conduct, in good faith and to the appropriate individual or using the CLV Integrity/Speak-Out Helpline. By doing so, we help CLV maintain a positive work environment. 

4.0 How we do Business 

4.1 We conduct business honestly and ethically

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

Human Rights

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

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

Privacy of Others

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

We must all take reasonable steps to ensure that we:

  • collect only the personal information we need for our business purposes.
  • are open and honest about how we collect, use and disclose personal information
  • take appropriate measures to keep such data secure in accordance with our policies and procedures
  • use and store data in accordance with the law
  • take the appropriate and required training to understand our privacy obligations and comply with regional Privacy Policies.

Preventing bribery, corruption and fraud

Our commitment is to deal with our customers and third parties in an honest and transparent manner. CLV strictly prohibits all forms of bribery, corruption, fraud and other improper, deceptive, or dishonest practices.  We do not give, receive, use or promise anything of value (including information) that could be perceived to unfairly influence a decision, improperly facilitate a process, or provide an improper gain or advantage to us or someone else.  Acts of bribery, corruption and fraud are simply not part of the way we do business. 

Know a bribe when you see one

Recognise that a bribe can take many forms – including payments, favors, charitable or political contributions, sponsorships, gifts, meals, entertainment, or travel. Appearances matter. Even if your intention is honorable, sometimes, just the appearance of impropriety may have negative consequences. If in doubt, ask your line manager or a member of the People Team. 

Money laundering, tax evasion and illicit financing

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

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

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

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

4.2 We celebrate diversity and inclusion 

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

4.3 We respect all and treat everyone equitably 

CLV is committed to providing a workplace which is free from bullying, harassment, unlawful discrimination, sexual assault and sexual harassment. We aim to ensure that everyone is treated with respect, dignity, and fairness in an environment that promotes positive working relationships.

At CLV, employees are expected to treat everyone fairly and without prejudice, discrimination or harassment. We value and encourage diversity in opinions and viewpoints and encourage employees to respect and take into consideration the opinions of others, working collaboratively to reach department and company goals.

4.4 We maintain a safe and healthy workplace

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

We also conduct business in a way that respects the health and safety of our customers and residents and the communities in which we operate.

Every employee is responsible for the protection of safety, health and security at the workplace to the extent required by their duties and to the best of their knowledge, ability, and experience. This requires employees to always follow safe work practices and to assist others.

Whenever there is a workplace injury or a hazardous situation, it is an employee’s responsibility to follow the Group Incident Reporting Procedure and immediately alert your on-duty manager. Where escalation is required (level 3 or 4 incident, or a hazard threatening safety) and you cannot reach the on-duty manager, you must escalate up the management line until contact is made.

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

In addition to this:

  • we do not tolerate the illegal use of alcohol and/ or drugs or other substances on any of our premises or on university grounds.
  • we have zero tolerance for threats of any kind, fighting, or other acts of violence against employees, customers, visitors, or guests by any person (including shouting).
  • illegal weapons or anything that could possibly be deemed to be an illegal weapon (including personal defense items) and explosives are absolutely prohibited from all CLV properties (whether they be owned or managed for third parties including our University partners).

4.5 We act in the best interests of CLV 

Conflicts of interest 

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

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

Understand the rules about gifts, hospitality and entertainment

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

Connecting responsibly through social media

Social media offers a great way to exchange ideas, promote our villages, engage with customers and build relationships. However, you should be smart and use it in a way that is consistent with our values and our policies.

Because of the risk for improper use, however, we have adopted a few key guidelines to follow when posting to social media:

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

Responding to enquiries 

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

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

Be careful with your communications 

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

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

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

Ask yourself: 

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

4.6 We safeguard our company assets 

Protecting our assets

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

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

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

Here are some more specific examples to help guide you: 

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

Information and data security

In the course of your employment at CLV, you may have access to a variety of information that we refer to as “Business Information.”

Depending on the type of information, there are specific precautions we must take to protect CLV, other employees, stakeholders and customers, and, in many cases, ourselves, from the unlawful and inappropriate use or disclosure of that information.

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

Our financial books and records are complete and accurate

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

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

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

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

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

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

Intellectual Property Assets

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

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

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

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

Access and Monitoring, including Acceptable Use of ICT Resources

Our policy on Acceptable Use of ICT Resources outlines that our ICT services and systems must not be used in any way that could be considered inappropriate.

To ensure that our ICT resources are properly used, CLV undertakes access and monitoring activity, including using system monitoring software.

CLV also uses CCTV as part of our ongoing business operations, and access and monitoring also extends to reviewing CCTV footage as outlined in relevant regional policies.

All access and monitoring may be done at any time without notice to employees and will be conducted in accordance with applicable workplace surveillance legislation.

Please ensure you familiarise yourself with the requirements of the Acceptable Use of ICT Resources Policy and other relevant policies and procedures, which contain additional and more detailed information

4.7    We safeguard CLV’s reputation

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

Compliance with laws, regulations, policies and procedures

CLV requires and expects its employees to:

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

Excellence in performance

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

Dress and presentation

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

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

Personal relationships

Employees are encouraged to socialise and develop professional relationships in the workplace, provided these relationships do not interfere with the work performance of either individual, or with the effective functioning of the workplace.

Employees who engage in personal relationships (these include romantic or physical, current or past, isolated or continuing) must be aware of their professional responsibility to immediately make their line manager(s) aware of the relationship. Both parties are responsible for assuring that the relationship does not raise concerns of favouritism, bias, ethics and conflict of interest.

Romantic or physical relationships between employees or with Resident Assistants, where one individual has influence or control over the other’s conditions of employment, are inappropriate. These relationships, even if consensual, may ultimately result in conflict or difficulties in the workplace. If such a relationship exists or existed, they must be disclosed to a member of the People Team and/or your line manager immediately.

CLV reserves the right to assess potential conflicts and may make changes in roles or reporting lines if deemed appropriate. Please also refer to your local Village Rules and/or regional policies which provide further guidance about personal relationships, including relationships with residents. 

Personal community activities

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

Political activities

CLV respects your right to engage in personal political activities, but again, you must do so on your own time, with your own resources.

You are not permitted to use CLV time, property or equipment for personal political activities without prior authorisation.

We minimize our environmental footprint

We are committed to measuring and monitoring the impact our business has on the natural environment and to taking actions to minimise this.

The development and operation of our student villages use materials derived from the natural environment, energy and water and creates waste.  Each of us has a role to play in ensuring that we are transitioning away from fossil fuels towards renewable energy sources to cut our greenhouse gas emissions, using resources efficiently and designing our waste.

All CLV employees are expected to ensure that our operations comply with environmental laws and regulations.

4.9 Reporting behaviour or conduct that contravenes the Code of Conduct

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

Alternatively, you can also make a report personally, by proxy or anonymously, on the CLV Integrity/Speak-Out Helpline – details of which can be found in every work location group-wide, and also on the CLV website. 

5.0 Regional Variation 

There are a number of regional policies and procedures (in force from time to time) which you should also familiarize yourself with, which supplement and align to the Code of Conduct.

United States

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

CLV Group Code of Conduct Endorsement

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