Tutor Code of Conduct

This Code of Conduct sets out the professional standards expected of every tutor who uses Fonetic English (FE) to teach students. It is part of the agreement between Fonetic English Pty Ltd (FEPL) and each tutor, and sits alongside the Tutor Terms. By using FE to deliver lessons, a tutor agrees to comply with this Code.

How to read this Code. Most provisions apply to all lessons. Provisions that apply only when teaching students under 18 are flagged [MINOR LESSONS] and shaded. As a general guide: most contact and parent-presence rules in sections 3 and 5 apply when the student is a minor; the professional standards in section 6 apply to all lessons; the firm contractual commitments in the Tutor Terms apply to all tutoring relationships. If you teach only adults, the [MINOR LESSONS] provisions do not apply to you — but they will apply the moment you accept a student under 18, so please read them now.

How this Code fits with the Tutor Terms. The Tutor Terms include two firm commitments — not to cause harm to anyone connected to the tutoring relationship, and not to initiate contact with the student or their family or friends outside lessons. These are absolute and cannot be varied. This Code sets out the professional standards FE expects, and the operational rules and defaults for how lessons are conducted. Some of the rules in this Code are defaults that the parent and tutor can vary in writing; others are firm. The Code makes clear which is which.

1. Purpose and who this Code applies to

1.1 Purpose. This Code exists to protect students, to protect tutors, and to protect the integrity of FE. Good teaching is built on trust — trust from students that the lesson environment is safe and professional, trust from parents that their children are in good hands, and trust from FEPL that tutors who carry the FE name behave in a way that reflects well on the system.

1.2 Application. This Code applies to any tutor who has accepted the Tutor Terms with FEPL and who uses FE to deliver lessons, whether the student is an adult or a minor, and whether the lesson is delivered online, in person, or in a hybrid format.

1.3 Minors. For the purposes of this Code, a minor is any student under 18 years of age, or under the age of majority in the student’s jurisdiction if that age is higher. Provisions flagged [MINOR LESSONS] apply only to lessons with minors and to tutors who teach any minors.

1.4 Local law prevails if stricter. Where the law that applies to you or to your student imposes standards stricter than this Code, you must comply with the stricter standard.

1.5 Acceptance. You accept this Code at registration by ticking a dedicated acknowledgement, separate from the acknowledgements you are asked to provide for the Tutor Terms, the Conditions of Use, and the Privacy Policy. Your acceptance is recorded against the version of this Code shown to you at registration.

2. Credentials and background checks

2.1 Identity. You warrant that the identity details you provide to FEPL are accurate and current.

2.2 Teaching credentials. You warrant that any teaching qualifications, certifications, or experience you claim publicly or on FEPL-facing materials are genuine, current, and verifiable.

2.3 [MINOR LESSONS] Background checks. Before teaching any minor under FE, you must hold a current and valid child-safety background check appropriate to your jurisdiction:

• in Australia, a Working With Children Check (or equivalent in each state or territory);
• in the United Kingdom, an enhanced Disclosure and Barring Service (DBS) check;
• in the United States, background checks required by the state in which you are located;
• in any other jurisdiction, the equivalent child-safety clearance issued by a competent authority, or, where no such check is issued in your jurisdiction, a current police clearance certificate together with a signed declaration that you have no adverse finding relating to work with children.

2.4 [MINOR LESSONS] Showing the check. You must be willing to show your background check to a parent on request before teaching their child. You must also notify FEPL within 7 days if the check lapses, is revoked, or is the subject of any adverse finding.

2.5 No adverse history. You warrant that you have not been the subject of any conviction, adverse disciplinary finding, or prohibition relating to work with children, abuse, harassment, fraud, or professional misconduct. You will notify FEPL in writing if such a matter arises at any time during your use of FE.

3. Contact with minor students and families

The Tutor Terms include a firm commitment that if you are tutoring a minor, you will not initiate contact with the person you are tutoring, or with their family or friends, outside scheduled lessons. That commitment cannot be varied by any agreement with the parent. The rules below operationalise that commitment and provide additional default protections that the parent and tutor may agree to vary in writing.

Firm rules

3.1 [MINOR LESSONS] No initiation of contact with a minor student outside lessons. You will not initiate contact with a minor student you are tutoring, or with any sibling or friend of that student, outside scheduled lessons. You may initiate contact with the parent about scheduling, materials, billing, lesson follow-up, progress, concerns, and other tutoring matters. You may also respond to messages and calls from the student during ordinary tutoring exchanges where the parent is the recipient or has visibility. This rule is firm and not subject to variation.

3.2 [MINOR LESSONS] Lesson communications with minors are visible to the parent. For minor students, every message you send to or receive from the student must be visible to the parent — either because the parent is copied on the message, or because the message is on a platform the parent can review, or because the parent is the registered account-holder with whom you are actually corresponding. This rule is firm.

Defaults the parent and tutor may vary in writing

3.3 [MINOR LESSONS] Personal contact details. For minor students, the default is that you do not exchange personal contact details with the student or their family — personal phone numbers, personal email addresses, social-media handles, messaging-app contacts, home addresses. The parent and you may agree in writing to exchange specific contact details where this is helpful for the relationship (for example, a direct number for last-minute scheduling). Record the agreement in writing — an email exchange is enough. For adult students, contact arrangements are at the discretion of the tutor and the student.

3.4 [MINOR LESSONS] Social-media connection. The default is that you do not connect on any social-media platform with a student who is a minor, either during the teaching relationship or afterwards. The parent and you may agree to vary this in writing where there is good reason; think carefully before doing so.

3.5 [MINOR LESSONS] In-person meetings outside scheduled lessons. For minor students, the default is that you do not arrange or accept in-person meetings outside scheduled lessons for purposes connected with the tutoring relationship. The parent and you may agree to vary this in writing. For adult students, in-person meetings outside scheduled lessons are at the discretion of the tutor and the student.

Where you have a separate professional relationship with the student

3.6 Other relationships. Where you have a separate professional relationship with the minor student outside tutoring — for example, you are the student’s school teacher, sports coach, or family friend — that other relationship is governed by its own professional norms. The rules above apply to your tutoring relationship. Communications about tutoring still go through the parent or are initiated by the parent. Communications and contact in your other professional capacity are not affected by this Code.

4. Recording of lessons

FE supports recording of online lessons with a minor student where the parent and tutor have agreed it. Whether to record, how the recording is stored, and how long it is kept are matters for the parent and tutor to agree. For adult students, the equivalent agreement is between the student and the tutor.

Some children may be uncomfortable being recorded — for example, a child who stutters or who is self-conscious about hearing or speech difficulties. The decision to record should take account of how the child responds. The parent is the right person to make this judgement; you as the tutor should respect what they decide.

The Parent Safeguarding Notice for parents discusses recording as one of the things parents may want to consider and ask the tutor about when engaging a tutor for a child.

4.1 Where you and the parent agree to record. You must use a conferencing tool with a built-in recording function (Zoom, Microsoft Teams, Google Meet, or similar). You must state at the start of every recorded lesson that the lesson is being recorded. You must store recordings securely and provide them to the parent in line with what you have agreed.

4.2 Use of recordings. You may use recordings only for review with the student of that student’s own lesson, your own reflective practice and professional development, and disclosure to FEPL or to a competent authority in connection with a safeguarding or quality concern. You must not share, publish, or repurpose recordings for marketing, training of other tutors, or any other purpose without the prior written consent of the student (or, for a minor, the parent).

4.3 Destruction on request. On written request from the student (or, for a minor, the parent), you must destroy any recording you hold, unless FEPL or a competent authority has directed that the recording be preserved for an active investigation.

5. [MINOR LESSONS] Parent presence at lessons

FE recommends that parents attend tutoring sessions with their minor children, particularly in the early weeks, because the parent can learn how to support their child when the child is using FE between lessons, and because the parent may know things about the child that are useful to tell the tutor. Whether the parent attends, and how often, is a matter for the parent and tutor to agree.

You should respect the arrangement the parent decides on. If the parent wants to attend, accommodate their presence professionally. If the parent does not want to attend (for example, because they trust your professional judgement, or because their child works better without them in the room), accept that decision.

Where you have specific reasons — for example, professional judgement that the child would learn better in a closed-room session — explain your view to the parent and let them decide.

6. Professional standards

We expect tutors to be professional. The standards in this section apply to every lesson and every interaction with students and families, regardless of age of the students.

Conduct during lessons

6.1 Lesson environment. You must teach from a neutral, tidy, non-private space. A home office, a study, a library, or a virtual background is appropriate. A bedroom, a bathroom, or any space that could reasonably be considered private is not, whether or not the camera shows the whole room.

6.2 Attire. You must dress in a manner appropriate to a professional teaching context. Your attire should be what you would wear to meet a student’s parent for the first time.

6.3 Camera on. For online lessons, your camera must be on for the full duration of every lesson. You should also ask the student to have their camera on, but you cannot compel this.

6.4 Quiet environment. You must teach in a quiet environment free from visible or audible interruption by other members of your household, pets, television, or other distractions, to the extent reasonably practicable.

6.5 No alcohol or intoxicants. You must not consume alcohol or any intoxicating substance before or during a lesson.

6.6 Professional language. You must use professional language throughout lessons. Profanity, sexual humour, and derogatory language are not appropriate.

6.7 Teaching content only. Lessons must be devoted to the teaching of English using FE and related language instruction. You should not use lesson time for other purposes.

6.8 No inappropriate content. You must not introduce into a lesson any content that is sexual, romantic, violent, discriminatory, politically partisan, religiously proselytising, or otherwise inappropriate for a professional teaching context.

6.9 [MINOR LESSONS] Personal matters with minors. You should not initiate or pursue conversations with a minor student about personal, family, romantic, or emotional matters. The tutoring relationship is professional and bounded by what teaching needs.

If a minor becomes upset during a lesson, you may and should respond with care — ask if they are alright, offer to pause, give them space. Asking what is wrong in the immediate moment is appropriate; pursuing the answer into deeper personal territory is not. If the child says they would rather not talk about it, accept that.

If a minor spontaneously discloses something significant — mistreatment at home, distress about a family situation, self-harm or other concerning content — respond with compassion in the moment, avoid follow-up questions that go further than the child has volunteered, and follow the reporting procedure in section 7. Tell the parent in your routine post-lesson communication unless doing so would put the child at risk.

6.10 No undisclosed third parties. No person other than you should be present in the room where you are teaching, whether on camera or off, unless their presence has been disclosed to the student (and, for a minor, to the parent) before the lesson begins. Disclosed presence is appropriate where the third party has a legitimate reason — another tutor in training, an experienced colleague observing for professional development, a co-teacher, or a responsible adult sharing the teaching space. Disclosure is the rule; the specific reason for the third party’s presence is between you and the student or parent.

Professional boundaries

6.11 Teacher–student boundary. The relationship between tutor and student is a professional teaching relationship of trust. You must not pursue or permit a romantic, sexual, financial, or close personal relationship with a current student, or with the parent of a current minor student.

6.12 Former students. The professional boundary extends for a reasonable period after a teaching engagement ends. For adult students, the professional boundary should be respected for at least 6 months after the last lesson. For minor students, you must not have any personal contact with the former student until the student is at least 18 years of age, and then only if initiated by the former student after that age.

6.13 Conflicts of interest. You must disclose to FEPL any personal, family, or business connection with a student or parent that could reasonably be perceived as a conflict of interest.

Money and gifts

6.14 No gifts or inducements. You must not send gifts, money, or other inducements to a student, or accept substantial gifts from a student or parent beyond a modest thank-you at the end of a teaching engagement.

6.15 No off-platform financial dealings. You must not enter into financial arrangements with a student or parent outside the booking and payment flow you have agreed for the tutoring — no loans, investments, or unrelated commercial arrangements.

Photographs and student data

6.16 No photographs. You must not take, request, or store photographs, screenshots, or video clips of students outside any agreed lesson recording. Where a recording exists, it is the only image record of the student that you are permitted to keep.

6.17 Minimum data. Collect only the information you need to teach effectively. You do not need home addresses, family compositions, photographs, or extensive personal histories.

6.18 [MINOR LESSONS] Parent as the contact. For minor students, the parent is the contact for all administrative and scheduling matters. You should not request or hold the minor’s personal email address, phone number, or home address.

6.19 Storage. Store student information securely. Do not share it with any third party except where required by law, by this Code, by FEPL, or by an approved platform.

6.20 Compliance with data-protection laws. You must comply with the data-protection laws that apply to you and to your student. If you are uncertain, the safest course is to minimise the data you collect and keep it securely.

7. Reporting safeguarding concerns

7.1 If you see or suspect something. If you observe, suspect, or are told anything that causes you concern about the welfare of a student — including abuse, neglect, self-harm, exploitation, or being at risk of any of these — you must:

• take any step immediately necessary to avoid further harm in the moment (for example, ending a lesson if a minor appears to be in danger);
• report the concern to FEPL at safeguarding@foneticenglish.com within 24 hours, and to any approved platform through which you accepted the booking;
• report the concern to local child-protection or law-enforcement authorities where required by the law of your jurisdiction or the student’s jurisdiction;
• preserve any relevant recording, message, or record and make it available to FEPL and to any investigating authority;
• not discuss the matter with any third party except FEPL, the approved platform, competent authorities, and your own legal or professional advisers.

7.2 If a concern is raised about you. If a concern is raised about your conduct, you must cooperate fully with FEPL’s review, provide any recording or record requested, and refrain from contacting the student, parent, or any other witness about the concern. FEPL may suspend your access to FE during the review. Suspension is a procedural step, not a finding.

7.3 Protection for good-faith reports. A tutor who reports a concern in good faith will not be penalised for the report, even if the concern is not ultimately substantiated. Good-faith reporting is a core professional obligation, not a risk to your standing.

8. Onboarding and continuing competence

8.1 Onboarding and ongoing practice. Before teaching with FE, you must read the FE Tutor Guide that applies to the students you will teach (the ESL Tutor Guide for non-native English speakers, the Native English Speakers Tutor Guide for native speakers, or both if you teach both groups), and confirm that you have read and understood this Code. You must apply the principles, methods, and practices set out in the Tutor Guide in your teaching. As FEPL updates the Tutor Guide and related materials, you must keep current with the updates and apply current practice.

8.2 FE Tutor Certification. FE offers a Tutor Certification programme through which you can demonstrate your competence in teaching FE. The programme has two tracks (ESL and Native English Speakers) and is being launched. We will tell you when it is available. The certification is optional but recommended; certified tutors will be listed on the FE tutor directory with their certification result, where they consent to publication.

8.3 Keeping current. You must keep up to date with changes to this Code and to FEPL’s other guidance. Material changes will be notified in advance; continued use of FE after the notice period constitutes acceptance.

9. Tutor-matching platforms and brand

9.1 Compliance with platform rules. Where you accept students through a third-party tutor-matching platform, you must also comply with that platform’s terms and code of conduct. Where the platform’s rules are stricter than this Code, the platform’s rules apply. Where this Code is stricter, this Code applies.

9.2 Brand. You may describe yourself as an FE-enabled tutor, or in such other terms as FEPL permits. You must not describe yourself in a way that implies FEPL employs you, supervises you day-to-day, or endorses your teaching specifically. FEPL provides FE; you provide the teaching.

10. Breach, suspension, and termination

10.1 Material breaches. The following are defined as material breaches of the Tutor Terms, entitling FEPL to suspend or terminate your access to FE immediately and without prior cure:

• breach of either of the firm commitments in the Tutor Terms (no harm; no initiation of contact);
• any breach of clause 2.3 (failure to hold required child-safety background check while teaching a minor);
• any breach of clause 3.1 (no initiation of contact outside lessons) or clause 3.2 (parent visibility for minor lessons);
• any breach of section 6 that, in FEPL’s reasonable view, poses a risk to a student or seriously compromises professional standards — in particular clauses 6.8 (inappropriate content), 6.9 (no probing of minors), 6.11 or 6.12 (professional boundary), 6.14 or 6.15 (gifts or off-platform financial dealings), or 6.16 (photographs);
• any breach of section 7 (reporting obligations); and
• any other conduct that, in FEPL’s reasonable view, poses a risk to a student or to the integrity of FE.

10.2 Other breaches. For other breaches of this Code, FEPL may issue a written warning, require remedial action, or suspend or terminate your access, depending on the seriousness of the breach and the circumstances.

10.3 Reporting to authorities. Where FEPL considers it necessary or is required by law, FEPL will report conduct to law-enforcement, child-protection, or regulatory authorities. FEPL may do so whether or not you continue as a tutor, and whether or not any investigation has been concluded.

10.4 Record of termination. Where FEPL terminates a tutor for conduct reasons related to the safety of students, FEPL may record the termination and may share the fact of termination with partner platforms and, where lawful, with other third parties with a legitimate interest.

10.5 Suspension pending investigation. FEPL may suspend your access to FE pending investigation of any claim or concern raised about you, whether by a parent, a student, a third party, or FEPL itself, where FEPL reasonably considers that suspension is appropriate while the matter is investigated. Suspension under this clause is a precautionary step, not a finding of breach. FEPL will conduct any investigation in a timely way and will inform you of the outcome.

11. Acknowledgement

By using FE to deliver lessons, you confirm that you have read and understood this Code, that you agree to comply with it, and that you understand that breach of certain provisions can result in immediate termination of your right to use FE and, where appropriate, in reporting to authorities.

This Code may be amended from time to time by FEPL. The current version is always available at foneticenglish.com. Material amendments will be notified in advance.