For the purposes of these regulations, the term “therapist” is used to signify anyone practicing counselling, healing, coaching or any other form of positive intervention or assistance with a client. Likewise the term “therapy” is used to signify the intervention used. SHTC and RIGHT are interchangeable and are the same entity, part of Scotlandtherapy Partners.
Therapy Standards
The default priority person in the therapy relationship is the client. The exception is where the interests of the therapist being compromised would lead in turn to the interests of a client or clients being negatively effected. The SHTC code of conduct requires the therapist to act in the best interest of the client. The code is in addition to adherence to the relevant legislation and NOS.
1. The therapist will act in the best interest of their clients. This is typically defined clearly in the relevant NOS for each therapy.
2. The therapy relationship is for the benefit of the client, and the emotional, physical and spiritual well being of the client will be the paramount concern of the therapist. Where a couple or group is being assisted, the overall well being of that group and its members will be balanced fairly and equitably.
3. All interventions and assistance methods must be offered subject to “informed consent” as per the definition contained in NOS.
4. The number of therapy sessions will be kept to the minimum required to achieve the aims the client wants to achieve through therapy. This may mean a specific intervention to assist or resolve an issue or issues. It may involve regular sessions of assistance, maintenance or coaching, if this is the desire of the client. The process must be agreed according to the needs of the client, and it's appropriateness reviewed on a regular basis.
5. Each therapist must comply with the Data Protection Act 1998, and to notify the client of the purpose for which Personal Data is processed. In particular if data is stored digitally, this must comply with regulations. “Hard copy” data must be kept in a secure and confidential location as per NOS guidelines.
6. Total confidentiality should be maintained, subject to the following exceptions:
a) Disclosures with the express permission of the client.
b) Disclosures which lead the therapist to believe that serious harm may befall a third party or the client themselves. This includes cruelty to animals and assaults on the personal property of third parties.
c) Disclosures that would leave the therapist liable to civil or criminal court procedure if not disclosed. This includes Children's Act and Anti-Terrorism legislation.
d) Requirements of any organisation body to which the therapist is answerable. The balance of confidentiality and the therapist's confidentiality policy should be as defined in the 1995 Counselling NOS.7. Therapists will be subject to the SHTC complaints procedure.
Therapists should make it clear to their clients exactly what level of confidentiality they will hold to before the therapy relationship begins. Although the therapist may break confidentiality if substantial self harm is likely or threatened, it must be recognised that in cases where the client presents with conditions that include self harming behaviour, a sensible level of danger should be established and agreed. The therapist should agree with the client emergency responses by the client in the event of self harming feelings or actions, including accessing emergency help lines and seeking medical attention.
Therapists should enter into a contract with their clients prior to commencement of therapy in which these and other exemptions to absolute confidentiality can be explicitly spelt out. This should be according to NOS guidelines on contracts and agreements and any “contract” orientated documents must be copied to the client under normal consumer legislation.
8. Therapists will adhere to the NOS National Occupational Standards for all modalities of therapy offered. Where modalities are not core models or therapies, the overall NOS for the major component of therapy will apply. In this scenario members must ensure that any specific additional criteria for other therapies are also adhered to above and beyond the core therapy NOS. For example a therapist classified primarily as a “Healer” may primarily adhere to the NOS Healing, but if they use counselling skills in their practice, they should adhere to any additional criteria from the Counselling NOS while using those skills and methods. Members are responsible for keeping up to date with new developments and NOS revisions.
9. Therapists must not interfere with medical treatments, contradict medical advice, seek to limit or change prescribed medications or offer an “alternative” to medical treatment. Where a medical condition, injury, illness or disease, therapists must take all reasonable steps to ensure that this is presented to and monitored by a medical doctor.
9.a Added 2016. Therapists may claim to treat medical conditions where they are fully qualified to provide a treatment which is either recommended for that condition by NICE, or where there is substantial and credible peer reviewed UK research to show that the treatment is clinically effective. Unless NICE recommendation applies, or the appropriate research exists and is quoted on any advertisement or claim to treat then the therapist must not make any claim to treat.
10. Therapists should be sensitive to the decision of the client's medical doctor in regard to complementary intervention. Although it is recognised that the client has the right to refuse medical treatment and seek alternatives, SHTC registered therapists must desist intervention if asked to do so on medical grounds by the client's medical doctor or specialist consultant.
11. Therapists must adhere to legal requirements regarding advertising standards, ensuring that all claims that are made adhere to the legal requirements of their place and area of practice.
12. Therapists must not misrepresent qualifications or claim to have qualifications that they are not entitled to. The use of the term “Dr” or “Doctor” must be avoided unless the therapist holds a medical qualification. Where either term is used, and medical qualification does not apply, the therapist must clearly state the nature of the award, and that it is not a medical qualification. In such cases the use must be restricted to the “biography” or “qualification list” section of materials. In no way must any therapist misrepresent their qualifications, in particular in relation to any inference of medical qualification. Therapists with research PhD awards should either use the appropriate letters after their name, or if using the Dr prefix, they must explicitly and clearly state the nature of this award.
12. Professorships may only be quoted where this applies to an actual current award or position, naming a position within a University or Seminary. These should be quoted in context, and it should be clear where the title originates from, what subjects it applies to, and what relevance it has to the therapy process. Such a position should be the Chair of a UK University / Seminary, or the UK Division of an International University / Seminary.
13. Religious awards and titles may only be quoted where faith or pastoral issues play a part in therapy processes, and the source and relevance must be stated.
14. Awards, titles and job descriptions should not be quoted unless these have direct relevance to the therapy process. The exception being in a specific “biography” section of any materials.
15. Therapists must only practice in their areas of competence, and may only claim to use models of therapy that they are competent in using, and insured to use. It is recognised that many areas of therapy have common methods, skills and processes. Where processes, skills and methods are used in the context of a core therapy, and not as stand alone therapies, this must be clear to the client. For example a “healer” who teaches “self hypnosis” should present themselves accurately as doing so, and not claim to be a qualified “hypnotherapist” unless they are actually accredited and competent in that job role. Likewise where job titles are regulated, or become regulated through future legislation, the therapist may point out that they have qualifications in that field in an accurate and clear manner, but must not claim a job title that they are not entitled to. For example a therapist with an award in psychology may quote that award in a “biography” or “qualification list” context, but may not call themselves a psychologist, since this is a regulated title. Therapists with core training that complete post qualification competency training may quote that therapy as something they are competent to do, but those therapists with short CPD courses should make clear that they have limited or specific trainings and not complete competency training.
16. Part of adherence to National Occupational Standards is regular self assessment and professional self evaluation. This, appropriate referral and appropriate levels of supervision and ongoing professional development are NOS requirements.
17.The therapist must hold appropriate professional liability insurance at all times. The therapist must also ensure compliance with Health and Safety, Fire Regulations and other regulations applicable to their place of practice. The therapist must also comply with the requirements of income tax registration and if appropriate VAT. The therapist should ensure that suitable first aid facilities are present at their place of work. First Aid facilities should include the presence of a first aid "appointed person", and where possible this should be in addition to the therapist themselves being an appointed person, certified with St Johns / St Andrews.
18. The therapist must take all reasonable steps to avoid non-professional contact with the client. Romantic involvement with a client is considered gross misconduct and totally inappropriate. Social contact with a client should be avoided as far as is reasonably possible. Where encouragement of a common interest is a genuine part of the client's programme of self development or therapy, this must be limited to serving the interests of the client. Using the interests of the client for personal amusement, personal social gratification or in any other way that does not serve the best interests of the client is inappropriate. The therapist should not use the therapeutic relationship to inappropriately gain financially, socially or in any other way not defined in the therapy contract. Personal gifts should only be accepted if token and appropriate in nature, and should be declared to a colleague or supervisor. In regard to contact in a non-confidential setting, or where the therapist is “off duty” and may have consumed substances (such as alcohol) that may effect judgement, the therapist should refuse to discuss personal or therapeutic information, and instead should arrange an appropriate time to discuss matters.
19. Assistance or therapy should only be offered at times when the therapist is in a “fit state” to do so. The therapist must not be under the influence of any substance, legal or not, that can influence their judgement. If unwell mentally, physically or spiritually, the therapist must not engage in therapy unless that state is a long term and appropriately managed condition. Therefore if the therapist suffers from a long term illness or disability, that condition need not prohibit practice if appropriately managed in order to prevent harm to the client. If however the condition is not managed, the therapist must desist until such time as appropriate management is under way.
20. Therapists should declare any previous criminal offences, outstanding criminal charges or pending / active criminal investigations to the SHTC. Cases will be assessed on the basis of risk to clients, with some offences restricting or preventing practice. Certain types of offence and spent conviction may not be considered a barrier to practice, but should be declared. Where therapists work with children, or those classified as vulnerable under mental health or learning disability classifications, a criminal check at the appropriate level must be carried out. Therapists with any previous, current or pending charges or convictions of a sexual nature, or involving children should immediately suspend practice and contact the SHTC for advice.
21. Therapists may not bring therapy or the SHTC into disrepute. They must not criticise other therapists in a libellous manner. Where there is an issue relating to another SHTC member, this should be processed via the official SHTC complaints procedure. SHTC members must not knowingly interfere with the treatment of, or take on clients who are currently clients of other SHTC members, unless this is agreed with the other SHTC member. Where the client is receiving assistance from a non-SHTC therapist, the other therapist should be informed via the client as a matter of professional courtesy that you are providing assistance.
22. Where referral is used, in part or in full, this should be according to NOS criteria and guidelines, taking reasonable care to ensure that the client is referred to a suitable and appropriate service. Where the client is not suitable for the therapy a therapist provides, the therapist should refer appropriately either to an appropriate source, or back to the medical doctor.
23. Where an issue arises not covered in the Code of Conduct, the therapist is expected to adhere to any requirements as stated in the NOS or required by existing legislation. Where these sources do not provide clarification, the therapist should contact the SHTC for advice. Where the therapist is unsure if they are adhering to the Code of Conduct, they should likewise contact the SHTC for advice. Where an immediate decision is required, the therapist should adhere to the concept “do no harm”, and should seek a witness or written client consent, informing the SHTC with due haste.
24. Use of SHTC or RIGHT logos, details, letters and certificates are all subject to trading standards legislation, the code of conduct and non-misrepresentation of membership or the Society itself. The therapist must clearly state the level of current membership, and in the event of leaving the Society must take reasonable steps to promptly amend advertising, stationary and internet listings to reflect this change. In such an event any current certificates of membership must be returned and insuring bodies should be notified.
25. [Added clause September 2007]. Ordinary members will adhere to NOS National Occupational Standards for therapies offered, and commit to work towards the same levels of accreditation as are held by full members. As an indication of reasonable timescale, since all members should complete ongoing professional development training on a year by year basis, Ordinary members are expected to select an appropriately accredited course for full membership within 18 months of joining as an Ordinary member. Where this is not possible for financial or other resource reasons, the member should inform the SHTC in writing or by email so that a revised date can be considered. Repeated failure to upgrade may result in refusal of membership renewal by the SHTC.
26. [Added clause September 2007] International members will adhere to the same standards as UK members. They will however take full responsibility for adhering to the requirements of their country of practice. Where their country of practice has rules or regulations that contradict NOS or SHTC rules, the member should follow the legal requirements of the country, but should also inform the SHTC of this fact.
27. [Added August 2008]. Further to trading standards modification of legislation, therapists should not call themselves "healer". It must be made clear that healing is holistic in nature and in no way an attempt to directly "treat" or "cure" or "heal" a specific condition. Thus we assist the client to "self heal" holistically, we do not "heal" them. If any title is used such as "Certified Healer" then it should be made clear that this is a title awarded by a specific body, and not a claim being made. Members are strongly advised to avoid such titles since they may cause a breech of legislation.
28. [Added May 2009] Due to new statutory regulation being brought into force by the HPC to cover psychologists (specific roles), psychotherapists and counsellors, members must ensure that they either avoid the use of regulated job titles or ensure compliance with the HPC and regulation.
29. [Added 2016] Trainee therapists under the conversion scheme must be clear to their clients that although they have completed initial training, they are undergoing additional training and supervision will require the use of anonymous session notes.
30 [Added 2016] Any supervision, research or other use of notes or client data must be anonymous and with the explicit prior agreement of the clients concerned. If there is a likelihood of this occurring, practitioners should insert an appropriate clause into their client agreement contracts.
31 [added 2016] Where members are also PSA AR members, in the event of a complaint, the SHTC will defer to the PSA AR's authority.
32 [added 2018] Panels assessing complaints are made up of volunteers from membership and representatives of training bodies.
33 [added 2018] Registered members must adhere to all legal requirements of their place of business and trade including data protection legislation in the UK and the rest of the EU.
Code of Conduct Effective updated 2018. Subject to amendment and change where necessary.
Therapy Standards
The default priority person in the therapy relationship is the client. The exception is where the interests of the therapist being compromised would lead in turn to the interests of a client or clients being negatively effected. The SHTC code of conduct requires the therapist to act in the best interest of the client. The code is in addition to adherence to the relevant legislation and NOS.
1. The therapist will act in the best interest of their clients. This is typically defined clearly in the relevant NOS for each therapy.
2. The therapy relationship is for the benefit of the client, and the emotional, physical and spiritual well being of the client will be the paramount concern of the therapist. Where a couple or group is being assisted, the overall well being of that group and its members will be balanced fairly and equitably.
3. All interventions and assistance methods must be offered subject to “informed consent” as per the definition contained in NOS.
4. The number of therapy sessions will be kept to the minimum required to achieve the aims the client wants to achieve through therapy. This may mean a specific intervention to assist or resolve an issue or issues. It may involve regular sessions of assistance, maintenance or coaching, if this is the desire of the client. The process must be agreed according to the needs of the client, and it's appropriateness reviewed on a regular basis.
5. Each therapist must comply with the Data Protection Act 1998, and to notify the client of the purpose for which Personal Data is processed. In particular if data is stored digitally, this must comply with regulations. “Hard copy” data must be kept in a secure and confidential location as per NOS guidelines.
6. Total confidentiality should be maintained, subject to the following exceptions:
a) Disclosures with the express permission of the client.
b) Disclosures which lead the therapist to believe that serious harm may befall a third party or the client themselves. This includes cruelty to animals and assaults on the personal property of third parties.
c) Disclosures that would leave the therapist liable to civil or criminal court procedure if not disclosed. This includes Children's Act and Anti-Terrorism legislation.
d) Requirements of any organisation body to which the therapist is answerable. The balance of confidentiality and the therapist's confidentiality policy should be as defined in the 1995 Counselling NOS.7. Therapists will be subject to the SHTC complaints procedure.
Therapists should make it clear to their clients exactly what level of confidentiality they will hold to before the therapy relationship begins. Although the therapist may break confidentiality if substantial self harm is likely or threatened, it must be recognised that in cases where the client presents with conditions that include self harming behaviour, a sensible level of danger should be established and agreed. The therapist should agree with the client emergency responses by the client in the event of self harming feelings or actions, including accessing emergency help lines and seeking medical attention.
Therapists should enter into a contract with their clients prior to commencement of therapy in which these and other exemptions to absolute confidentiality can be explicitly spelt out. This should be according to NOS guidelines on contracts and agreements and any “contract” orientated documents must be copied to the client under normal consumer legislation.
8. Therapists will adhere to the NOS National Occupational Standards for all modalities of therapy offered. Where modalities are not core models or therapies, the overall NOS for the major component of therapy will apply. In this scenario members must ensure that any specific additional criteria for other therapies are also adhered to above and beyond the core therapy NOS. For example a therapist classified primarily as a “Healer” may primarily adhere to the NOS Healing, but if they use counselling skills in their practice, they should adhere to any additional criteria from the Counselling NOS while using those skills and methods. Members are responsible for keeping up to date with new developments and NOS revisions.
9. Therapists must not interfere with medical treatments, contradict medical advice, seek to limit or change prescribed medications or offer an “alternative” to medical treatment. Where a medical condition, injury, illness or disease, therapists must take all reasonable steps to ensure that this is presented to and monitored by a medical doctor.
9.a Added 2016. Therapists may claim to treat medical conditions where they are fully qualified to provide a treatment which is either recommended for that condition by NICE, or where there is substantial and credible peer reviewed UK research to show that the treatment is clinically effective. Unless NICE recommendation applies, or the appropriate research exists and is quoted on any advertisement or claim to treat then the therapist must not make any claim to treat.
10. Therapists should be sensitive to the decision of the client's medical doctor in regard to complementary intervention. Although it is recognised that the client has the right to refuse medical treatment and seek alternatives, SHTC registered therapists must desist intervention if asked to do so on medical grounds by the client's medical doctor or specialist consultant.
11. Therapists must adhere to legal requirements regarding advertising standards, ensuring that all claims that are made adhere to the legal requirements of their place and area of practice.
12. Therapists must not misrepresent qualifications or claim to have qualifications that they are not entitled to. The use of the term “Dr” or “Doctor” must be avoided unless the therapist holds a medical qualification. Where either term is used, and medical qualification does not apply, the therapist must clearly state the nature of the award, and that it is not a medical qualification. In such cases the use must be restricted to the “biography” or “qualification list” section of materials. In no way must any therapist misrepresent their qualifications, in particular in relation to any inference of medical qualification. Therapists with research PhD awards should either use the appropriate letters after their name, or if using the Dr prefix, they must explicitly and clearly state the nature of this award.
12. Professorships may only be quoted where this applies to an actual current award or position, naming a position within a University or Seminary. These should be quoted in context, and it should be clear where the title originates from, what subjects it applies to, and what relevance it has to the therapy process. Such a position should be the Chair of a UK University / Seminary, or the UK Division of an International University / Seminary.
13. Religious awards and titles may only be quoted where faith or pastoral issues play a part in therapy processes, and the source and relevance must be stated.
14. Awards, titles and job descriptions should not be quoted unless these have direct relevance to the therapy process. The exception being in a specific “biography” section of any materials.
15. Therapists must only practice in their areas of competence, and may only claim to use models of therapy that they are competent in using, and insured to use. It is recognised that many areas of therapy have common methods, skills and processes. Where processes, skills and methods are used in the context of a core therapy, and not as stand alone therapies, this must be clear to the client. For example a “healer” who teaches “self hypnosis” should present themselves accurately as doing so, and not claim to be a qualified “hypnotherapist” unless they are actually accredited and competent in that job role. Likewise where job titles are regulated, or become regulated through future legislation, the therapist may point out that they have qualifications in that field in an accurate and clear manner, but must not claim a job title that they are not entitled to. For example a therapist with an award in psychology may quote that award in a “biography” or “qualification list” context, but may not call themselves a psychologist, since this is a regulated title. Therapists with core training that complete post qualification competency training may quote that therapy as something they are competent to do, but those therapists with short CPD courses should make clear that they have limited or specific trainings and not complete competency training.
16. Part of adherence to National Occupational Standards is regular self assessment and professional self evaluation. This, appropriate referral and appropriate levels of supervision and ongoing professional development are NOS requirements.
17.The therapist must hold appropriate professional liability insurance at all times. The therapist must also ensure compliance with Health and Safety, Fire Regulations and other regulations applicable to their place of practice. The therapist must also comply with the requirements of income tax registration and if appropriate VAT. The therapist should ensure that suitable first aid facilities are present at their place of work. First Aid facilities should include the presence of a first aid "appointed person", and where possible this should be in addition to the therapist themselves being an appointed person, certified with St Johns / St Andrews.
18. The therapist must take all reasonable steps to avoid non-professional contact with the client. Romantic involvement with a client is considered gross misconduct and totally inappropriate. Social contact with a client should be avoided as far as is reasonably possible. Where encouragement of a common interest is a genuine part of the client's programme of self development or therapy, this must be limited to serving the interests of the client. Using the interests of the client for personal amusement, personal social gratification or in any other way that does not serve the best interests of the client is inappropriate. The therapist should not use the therapeutic relationship to inappropriately gain financially, socially or in any other way not defined in the therapy contract. Personal gifts should only be accepted if token and appropriate in nature, and should be declared to a colleague or supervisor. In regard to contact in a non-confidential setting, or where the therapist is “off duty” and may have consumed substances (such as alcohol) that may effect judgement, the therapist should refuse to discuss personal or therapeutic information, and instead should arrange an appropriate time to discuss matters.
19. Assistance or therapy should only be offered at times when the therapist is in a “fit state” to do so. The therapist must not be under the influence of any substance, legal or not, that can influence their judgement. If unwell mentally, physically or spiritually, the therapist must not engage in therapy unless that state is a long term and appropriately managed condition. Therefore if the therapist suffers from a long term illness or disability, that condition need not prohibit practice if appropriately managed in order to prevent harm to the client. If however the condition is not managed, the therapist must desist until such time as appropriate management is under way.
20. Therapists should declare any previous criminal offences, outstanding criminal charges or pending / active criminal investigations to the SHTC. Cases will be assessed on the basis of risk to clients, with some offences restricting or preventing practice. Certain types of offence and spent conviction may not be considered a barrier to practice, but should be declared. Where therapists work with children, or those classified as vulnerable under mental health or learning disability classifications, a criminal check at the appropriate level must be carried out. Therapists with any previous, current or pending charges or convictions of a sexual nature, or involving children should immediately suspend practice and contact the SHTC for advice.
21. Therapists may not bring therapy or the SHTC into disrepute. They must not criticise other therapists in a libellous manner. Where there is an issue relating to another SHTC member, this should be processed via the official SHTC complaints procedure. SHTC members must not knowingly interfere with the treatment of, or take on clients who are currently clients of other SHTC members, unless this is agreed with the other SHTC member. Where the client is receiving assistance from a non-SHTC therapist, the other therapist should be informed via the client as a matter of professional courtesy that you are providing assistance.
22. Where referral is used, in part or in full, this should be according to NOS criteria and guidelines, taking reasonable care to ensure that the client is referred to a suitable and appropriate service. Where the client is not suitable for the therapy a therapist provides, the therapist should refer appropriately either to an appropriate source, or back to the medical doctor.
23. Where an issue arises not covered in the Code of Conduct, the therapist is expected to adhere to any requirements as stated in the NOS or required by existing legislation. Where these sources do not provide clarification, the therapist should contact the SHTC for advice. Where the therapist is unsure if they are adhering to the Code of Conduct, they should likewise contact the SHTC for advice. Where an immediate decision is required, the therapist should adhere to the concept “do no harm”, and should seek a witness or written client consent, informing the SHTC with due haste.
24. Use of SHTC or RIGHT logos, details, letters and certificates are all subject to trading standards legislation, the code of conduct and non-misrepresentation of membership or the Society itself. The therapist must clearly state the level of current membership, and in the event of leaving the Society must take reasonable steps to promptly amend advertising, stationary and internet listings to reflect this change. In such an event any current certificates of membership must be returned and insuring bodies should be notified.
25. [Added clause September 2007]. Ordinary members will adhere to NOS National Occupational Standards for therapies offered, and commit to work towards the same levels of accreditation as are held by full members. As an indication of reasonable timescale, since all members should complete ongoing professional development training on a year by year basis, Ordinary members are expected to select an appropriately accredited course for full membership within 18 months of joining as an Ordinary member. Where this is not possible for financial or other resource reasons, the member should inform the SHTC in writing or by email so that a revised date can be considered. Repeated failure to upgrade may result in refusal of membership renewal by the SHTC.
26. [Added clause September 2007] International members will adhere to the same standards as UK members. They will however take full responsibility for adhering to the requirements of their country of practice. Where their country of practice has rules or regulations that contradict NOS or SHTC rules, the member should follow the legal requirements of the country, but should also inform the SHTC of this fact.
27. [Added August 2008]. Further to trading standards modification of legislation, therapists should not call themselves "healer". It must be made clear that healing is holistic in nature and in no way an attempt to directly "treat" or "cure" or "heal" a specific condition. Thus we assist the client to "self heal" holistically, we do not "heal" them. If any title is used such as "Certified Healer" then it should be made clear that this is a title awarded by a specific body, and not a claim being made. Members are strongly advised to avoid such titles since they may cause a breech of legislation.
28. [Added May 2009] Due to new statutory regulation being brought into force by the HPC to cover psychologists (specific roles), psychotherapists and counsellors, members must ensure that they either avoid the use of regulated job titles or ensure compliance with the HPC and regulation.
29. [Added 2016] Trainee therapists under the conversion scheme must be clear to their clients that although they have completed initial training, they are undergoing additional training and supervision will require the use of anonymous session notes.
30 [Added 2016] Any supervision, research or other use of notes or client data must be anonymous and with the explicit prior agreement of the clients concerned. If there is a likelihood of this occurring, practitioners should insert an appropriate clause into their client agreement contracts.
31 [added 2016] Where members are also PSA AR members, in the event of a complaint, the SHTC will defer to the PSA AR's authority.
32 [added 2018] Panels assessing complaints are made up of volunteers from membership and representatives of training bodies.
33 [added 2018] Registered members must adhere to all legal requirements of their place of business and trade including data protection legislation in the UK and the rest of the EU.
Code of Conduct Effective updated 2018. Subject to amendment and change where necessary.
