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1. Purpose

This Procedure is underpinned by the ANA Ethical Practice Guidelines (“AEPG”) and ANA Feedback Policy. It sets out how ANA will consider and respond to concerns about members not adhering to the AEPG.

Non-adherence includes alleged or established breaches of the AEPG and conduct that may fall below the expected standards of the AEPG. It means being accountable for behaviour, professional standards, or conduct that creates significant risk to ANA, its members, and network, including participants in ANA Initiatives.

The aim of this procedure is to ensure that concerns are handled fairly, consistently, proportionately, and transparently, while protecting ANA's purpose as a professional body.

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2. Scope

This procedure applies to ANA Community members, employees, directors, volunteers, advisors, Chapter founding members, Special Interest Group leaders, committee members, and any individuals holding a recognised ANA role. Role performance may be accountable through the letter of appointment and only becomes a disciplinary matter where it involves non-adherence.

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Where an individual is an employee, any employment-related disciplinary matter will also be handled in accordance with applicable employment law, contractual obligations, and relevant workplace procedures. This procedure is not intended to replace statutory employment rights.

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ANA Network member participants and newsletter and neuroevent calendar subscribers, ANA initiative attendees, and public participants, are not normally subject to ANA’s Disciplinary Procedure solely by virtue of attending or engaging in ANA initiatives and activities. Where concerns arise in relation to misconduct when taking part in ANA initiatives and activities, they will normally be managed as participation matters.

Participation management may include refusing admission, reminding an individual of expected standards, removing them from an event or group, restricting future access to ANA participatory spaces, declining further engagement, or taking other proportionate steps connected with the relevant activity.

Where the participation matter may include, but is not limited to serious breaches of safety (sexual harassment, abuse, discrimination, safeguarding concerns, intimidation, threats) and/or integrity (confidentiality, misuse of ANA resources, misuse of data, reputational harm), that may cause significant harm to ANA, its members, participants, or public trust, ANA may report or share relevant information with an appropriate external body, where necessary, lawful and proportionate.

Contractors, suppliers, sponsors, speakers, facilitators, partner representatives and other third parties will normally be managed through their respective contracts, agreements, terms of engagement, partnership arrangements, and/or event terms.

Use of ANA’s website, resources, and digital materials is governed separately by ANA’s Terms of Use.

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3. Principles of the Disciplinary Process

ANA will apply the following principles when handling the disciplinary process:

1. Fairness: individuals will be informed of the concern or allegation and given a reasonable opportunity to respond before any formal response/decision is made.

2. Proportionality: ANA will respond in a way that is proportionate to the seriousness, context and impact of the matter in hand.

3. Impartiality: decisions will be made by individuals who are not directly involved in the matter wherever reasonably possible.

4. Confidentiality: disciplinary matters will be handled confidentially, so far as this is reasonably possible and consistent with the need to investigate and act swiftly and appropriately.

5. Evidence-based decision-making: decisions will be based on available evidence, including relevant documents, communications, witness statements, meeting notes, and the responses of the individuals involved.

6. Protection of standards: ANA may act where conduct risks undermining the ANA Guiding Principles.

7. Protection from retaliation: ANA will not tolerate retaliation against any individual who raises a concern in good faith or who participates honestly in this disciplinary process. Any alleged retaliation may itself be considered under this Procedure.

8. Right of appeal: individuals subject to formal disciplinary action will have the right to appeal the final decision.

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4. Matters that may give rise to disciplinary action

Examples may include, but are not limited to:

• conduct that breaches the ANA Ethical Practice Guidelines (AEPG);

• behaviour that may bring ANA, applied neuroscience, or the wider profession into disrepute;

• harassment, bullying, discrimination, victimisation, intimidation, or abusive behaviour;

• misuse of ANA’s name, platform, membership, intellectual property (IP), or resources;

• serious breach of confidentiality

• dishonesty, fraud, bribery, and misrepresentation

• conflicts of interest that are not properly disclosed or managed;

• behaviour that compromises trust or professional boundaries;

• conduct that undermines ANA’s mission or governance;

• failure to cooperate with a reasonable investigation under this procedure.

 

5. Informal resolution

Where appropriate, minor concerns, may be addressed through informal resolution.

Minor concerns are concerns that are limited in seriousness, impact and risk, and which can reasonably be addressed through informal discussion, clarification of expectations, guidance, support, or agreed corrective action.

Concerns are not serious in nature where there is no apparent malicious intent, no significant harm or safeguarding issue evidenced, no harassment or discrimination, no breach of confidentiality, and no wider risk to ANA’s integrity or public trust.

Informal action may include:

• a formal conversation with the individual;

• clarification of expected standards;

• support, guidance, or signposting;

• agreement of corrective action;

• an informal written reminder or note of expectations;

• monitoring for an agreed period;

• mediation or facilitated discussion, where suitable.

 

6. Initial assessment

When a concern is received or identified, ANA will carry out an initial assessment to decide whether:

• further information is needed;

• no further action is required;

• the matter should be resolved through informal resolution;

• temporary precautionary action is required;

• the matter should be referred to another process, regulator, employer, professional body, safeguarding authority, or legal authority;

• the matter should proceed to formal investigation.

The initial assessment does not determine whether the allegation is upheld. Its purpose is to decide the appropriate route for handling the concern.

 

7. Precautionary action

Where necessary, ANA may take precautionary action while a matter is being considered or investigated. This may include temporary suspension from ANA membership, role duties, and restriction of access to ANA platforms.

Precautionary action is not a disciplinary sanction and does not imply that the allegation has been upheld. It may be used where ANA considers it necessary to protect individuals involved, preserve evidence or confidential information, and protect the integrity of the process.

 

8. Formal investigation

Where formal investigation is required, ANA will appoint an investigator or panel to investigate the matter. Wherever reasonably possible, the investigator or panel should not have a direct conflict of interest in the matter.

The investigation may include:

• reviewing written complaints or concerns;

• reviewing relevant documents, correspondence, recordings, records, policies, or platform activity;

• speaking with the complainant, respondent, witnesses, or relevant ANA representatives;

• requesting a written response from the individual concerned;

• gathering any other information reasonably required.

The individual concerned will normally be informed of the nature of the concern or allegation and given a reasonable opportunity to respond.

ANA may vary the investigation process where necessary to protect confidentiality, safeguarding, or any legal obligations.

 

9. Disciplinary meeting or panel

If, following investigation, ANA considers that there is a case to answer, the matter may be referred to an internal disciplinary meeting or panel.

The individual concerned will be given written notice of the meeting, including:

• the nature of the allegation or concern;

• relevant evidence or a summary of the evidence;

• the possible outcomes;

• the date, time and format of the meeting;

• their right to submit a written response;

• their right to be accompanied, where applicable.

The meeting may take place online or in person. The individual will have a reasonable opportunity to respond to the allegation or concern, present relevant information, and answer questions.

If the individual does not attend without good reason, ANA may proceed in their absence based on the available evidence.

 

10. Right to be accompanied

Where a formal disciplinary meeting is held, the individual may be accompanied by a suitable person, such as a colleague, fellow member, or other appropriate supporter, subject to the process.

The companion may support the individual and, where appropriate, help present their case. The companion may not answer questions on the individual’s behalf unless ANA agrees this as a reasonable adjustment or for other appropriate reason.

For employees or workers, any statutory right to be accompanied will apply.

 

11. Possible outcomes and sanctions

Following a disciplinary investigation or panel, ANA may decide that:

• the allegation is not upheld;

• no further action is required;

• informal guidance or corrective action is appropriate;

• a written warning should be issued;

• conditions should be placed on continued membership, role, registration, and/or participation;

• training, supervision, mentoring, or reflective practice should be required;

• suspension or removal from a role or responsibility;

• access to ANA platforms, groups, events, or activities should be restricted;

• suspension or termination of membership for a defined period or permanently;

• any other ANA status should be suspended or removed, where applicable;

• the matter should be referred to another body, regulator, employer, safeguarding authority, or legal authority.

Any sanctions will be proportionate to the seriousness and circumstances of the matter, including any repeat pattern of behaviour, impact on others, insight shown, remedial action taken, risk to ANA, members and public trust.

 

12. Serious misconduct

Some evidenced matters may be treated as serious misconduct and may justify immediate removal from role, termination of membership, or other serious sanction if upheld.

Examples of serious misconduct may include:

• bullying, harassment, discrimination, or victimisation;

• violence, threats, intimidation, or abusive conduct;

• safeguarding concerns or serious boundary violations;

• fraud, bribery, dishonesty, or deliberate misrepresentation;

• gross negligence or reckless conduct;

• serious breach of confidentiality;

• knowingly misusing ANA funds, resources, name, intellectual property, or confidential information;

• conduct that seriously damages, or risks damaging, ANA’s reputation or public trust;

• serious breach of the AEPG;

• failure to disclose or manage a serious conflict of interest;

• conduct that places individuals, communities, clients, members, or the public at risk.

This list is not exhaustive.

 

13. Written outcome

ANA will provide the individual with the outcome in writing. The written outcome will normally include:

• the decision;

• whether the allegation is upheld, partially upheld, or not upheld;

• the reasons for the decision;

• any sanction or action to be taken;

• the timescale or duration of any sanction;

• any conditions for continued involvement with ANA;

• the right of appeal and the appeal deadline.

ANA may inform the complainant that the matter has been concluded, while respecting confidentiality and data protection obligations.

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14. Appeals

An individual may appeal a formal disciplinary decision where they believe that:

• the procedure was not followed fairly;

• relevant evidence was not properly considered;

• new evidence has become available;

• the decision was unreasonable or disproportionate;

• there was bias or a conflict of interest in the decision-making process.

The appeal outcome will be confirmed in writing to the individual concerned. Where appropriate, ANA may inform the complainant that the matter has concluded, while respecting confidentiality and data protection obligations.

Where reasonably possible, the appeal will be considered by a person or panel not previously involved in the decision. The appeal decision may:

• uphold the original decision;

• overturn the decision;

• vary the sanction;

• require further investigation or reconsideration.

The appeal outcome will be confirmed in writing to all parties involved. The appeal decision will be final.

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15. Confidentiality and records

ANA will keep appropriate records of disciplinary matters, including complaints, evidence, investigation notes, decisions, sanctions, and appeals.

Records will be handled in accordance with UK data protection law and ANA’s records-retention arrangements. Information will only be shared where there is a legitimate need to do so, including for governance, safeguarding, legal, regulatory, or professional standards.

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16. Conflicts of interest

Anyone involved in investigating, hearing, or deciding a disciplinary matter must declare any actual, potential, or perceived conflict of interest.

Where a conflict exists, ANA will take reasonable steps to manage it. This may include appointing an alternative investigator and/or appeal panel member.

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17. Safeguarding, legal and regulatory matters

Where a concern involves safeguarding, criminal conduct, serious risk, professional regulation, or legal obligations, ANA may refer the matter to an appropriate external body.

ANA may pause, adapt, or continue its own process depending on the circumstances, including where external proceedings are underway.

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18. Relationship with other ANA procedures

This procedure should be read alongside the ANA Ethical Practice Guidelines (AEPG), ANA Complaints Policy, Letter of Appointment, and any applicable volunteer procedures.

Where more than one procedure may apply, ANA will decide the most appropriate route, considering fairness, proportionality, legal obligations, and protection of ANA and community members.

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19. Review

This procedure will be reviewed periodically by ANA to ensure that it remains current, fair, proportionate, and aligned with ANA’s guiding principles, professional standards, and any relevant external body requirements.

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ANA Professional Conduct and Disciplinary Procedure v1.4

July 2026