Ethical codes in adult education as subjects of comparative analysis

In the process of professionalisation of adult educators, a significant role is played by qualification, educational and evaluation standards. However, they do not often deal with ethical questions which can arise from their relationship with participants of the educational process, from their membership in professional associations or from the relationship with an educational institution. This gap is filled by ethical codes, which are not legal standards but they are adult educators’ voluntary obligations. The importance of codes was a reason for the comparison of 26 ethical codes aiming to find their common features and non-standard regulations, to point out the prevailing structures and contents and disciplinary measures when the code is violated. The contribution of this study is to enrich the andragogical theory with a deeper understanding of the purpose of ethical codes, their structural elements and content. From the point of view of education policy, an analysis of codes can work as a specific monitoring of the market of educational services. It can serve for designing certification courses of adult educators as well as subjects in graduate studies in andragogy. The limitation of this study lies in the fact that the selection of codes was limited to codes written in four languages; however, one of them was English, which is a world language. As for the territorial scope, codes cover North America, Europe, Australia and New Zealand.

advisors, online tutors and others. Interest organisations associating and representing these andragogical sub-professions gradually create their own specific codes, which reflect particular requirements for their performance and for the ethical conduct of their representatives. Such codes are the focus of this article.

Ethics in educational professions and ethical codes
Professional ethics complements general ethics. It enhances effectiveness of the execution of the given profession, influences its prestige, helps to deal with conflicts, speeds up decision-making, provides moral and self-development impulses, defines and justifies crossing of borders of general norms and, in certain cases, it demands that special obligations be considered as essential (Środa, 2005). Moral decisions are a common part of the theory and practice of adult education and adult educators' activities can have farreaching consequences for other people, which can encourage and help them when acquiring new knowledge, support them in problem solving, open new perspectives and semantic horizons to them, or to intimidate, discourage, or exclude them from educational programmes (Schubert, Beneš, Krystoň, Lorenzová, Pavlov & Skúpa, 2018). Ethical issues related to the practice of andragogic professions need to be discussed and explored whether the professional ethics, in our case the ethics of adult educators, has to have the character of a code or not (Zając, 2016).
Ethical requirements for adult educators professional performance are usually included in codes of ethics. These codes can be the only normative document presenting adult educators behaviour, roles and tasks, or complementing the codes of practice or standards of practice. If they are the only norm, they often include provisions or requirements, which have the character of ethical rules and requirements for basic professional activities or tasks, and in educational professions, it is presupposed that ethical knowledge is not separated from professional knowledge (Forster, 2012). Some countries, for instance, Australia and New Zealand, formulate codes of ethics and conduct and Gilman (2005) states that 'the pragmatic reality is that they can, and often are, complementary'. International organisations such as UNESCO or the International Labour Organisation declare great support in developing professional ethics. According to them, codes of ethics or conduct should be established by teacher organisations since such codes greatly contribute to ensuring the prestige of the profession and the exercise of professional duties in accordance with agreed principles (Fredriksson, 2004as cited in van Nuland, 2009. Several main purposes of ethical codes for the public administration as a sphere related to adult education was proposed by Gilman (2005, p. 8-9): • codes of ethics increase the probability that people will behave in certain ways.
They do this partially by focusing on the character of their actions and partly by focusing on sanctions for violations. • good ethics codes can focus public servants on actions that result in doing the right things for the right reasons. Ethical behaviour should become a habit and effective codes allow public servants to test their actions against expected standards. • codes of ethics do not take away one's own moral autonomy or absolve the public servant from the obligation to reason. Codes of ethics provide at most a strong prima facie reason to act in a certain way. • codes of ethics can function as a professional statement. That is it expresses the public service's commitments to a specific set of moral standards. This has both cognitive and emotive value'.
[202] Malach Codes that have impact usually begin by asking what the behavioural objectives are, what the organizational objectives are, and what the political objectives are. Codes most often fail because they raise unrealistic expectations. Ethical values and principles in codes must have both cognitive and emotive elements. They must appeal to reason, as well as the emotional content of patriotism, loyalty or professionalism. The most successful codes have both administrative and criminal penalties associated with them that are appropriate and timely. (Gilman, 2005). Codes of professional ethics improve the attitude to the profession, they co-create its ethos and build traditions and thus differentiate representatives from given professional groups and increase their internal solidarity (Środa, 2005). Siegel (2000) defined four aims of the universal ethical code for adult educators. First, the code of ethics will provide guidance to adult educators concerning what constitutes appropriate practice. Secondly, the code of ethics will provide a policymaking direction to organizations and agencies engaged in adult education. Thirdly, the code of ethics will provide a common reference for the encouragement of dialogue among adult educators. Fourthly, the code of ethics will assist in communicating the shared values in the field of adult education. Authors of ethical codes usually formulate their purpose or aims in the preamble. For example, in the introduction to the Standards of Practice for Teaching Professions and Ethical Standards of Practice, the Canadian province Ontario states that they describe what it means to be a professional teaching in the given state, and they reflect a shared belief within the profession. They express goals and aspirations of teachers aiming to improve students' learning and prepare them for life in a democratic society. They are also a tool for the regulation, which includes sanctions for breaking the rules and requirements. Through an analysis of ethical codes, Pomianowska and Tołwińska-Królikowska (2005) drew a logical conclusion that they can have two kinds of functions, external functions and internal functions. External functions deal with the relationships with users of educational activities. The knowledge of principles which an adult educator should follow give clients a stronger sense of safety and possibility to appeal to these principles. The existence of a code increases trust in educators and creates educator's positive image. Codes can form ethical awareness and sensitivity and help decide in difficult situations. Kadlubeková (2016, p. 60) considers ethical principles to be 'generally applicable moral principles of conduct applicable to all andragogists, which should be respected and the compliance with them should be reflected in andragogists' conduct and acts in practice'. The author also described ethical principles derived from the comparison of existing sectoral ethical codes for the field of adult education. All these principles are equally important and presented here in a random order: principle of autonomy, principle of confidentiality, principle of competence, principle of doing no harm (noli nocere), principle of professional development, principle of usefulness and principle of fairness. In ethical codes for teachers, Göbelová (2015) presents five basic principles: respect and dignity, responsibility, justice, truth and moral integrity.
When examining the ethics of a specialised profession of an educational diagnostician, Wysocka (2013) distinguishes normative ethics and value (axiological) ethics. Normative ethics describes boundaries of the diagnostic work (prohibitions or things that are not allowed) and value ethics formulates basic values common to all social sciences (value of the human being, value of each individual, value of truth, responsibility and perfectionism). Using the value ethics, the author formulates ethical principles characterising the professionalism of a diagnostician, distinguishing principles describing personally formal competences and principles describing interpersonal competences (which could correspond to emotional elements according to Gilman), and ethical principles in projecting intervention and action dividing them into principles of process effectiveness and principles of purpose and methods of intervention (which would correspond to Gilman's cognitive elements). Göbelová (2015) presents similar distinction of applied professional ethics: descriptive ethics and normative ethics, which is closer to the creation of ethical codes because it characterises what is valid, authoritative and binding and describes norms and principles. A bind expresses what is binding for a teacher and it can be directed towards oneself (one's conscience), pupils, colleagues, parents and school, its wider community and society as a whole. Compared with teachers, adult educators have fewer binds, which are usually directed only towards oneself, education participants or employers.
A recommended content of universal codes for adult educators was formulated by Siegel (2000, p. 51-58) in the form of requirements for main lecturers' tasks and their actions and conduct towards students. Adult educators should: 1. Use expert knowledge and practice to a maximum degree. 2. Respect students' ethno-social and cultural differences and dignity. 3. Avoid the conflict of interests. 4. Maintain confidentiality in the relationship with students. 5. Respect students' unique and varied needs and show the sense of honesty, understanding and fairness. 6. Be sensitive to the possibility of a negative impact of the institutional policy on students, organisations as well as the whole society. 7. Present clear, complete and exact promotional information. 8. Offer financially responsible services and programmes with outcomes which are based on an objective and fair evaluation. 9. Encourage students' active and effective participation in the development of society. 10. Avoid harming students in whatever way.
A whole range of methodical handbooks and tools has been created for the writing of codes of ethics and codes of conduct for teaching professions and for their easier implementation in educational practice (Poisson, 2009;Department of Education and Training, 2006;Ethics Resource Center, 2001;Connecticut State Dep. of Education (CSDE), 2015). They include instructions for the preparation of a code with necessary structural elements, instructions for its adopting, reporting and sanctioning misconduct, reviewing the code and evaluating its impact. In some of them, there are instructions for dealing with ethical dilemmas in educational practice which also happen outside school teaching (CSDE, 2015).
For the creation and update of codes in the globalised world, transnational codes are created as examples and inspiration, they cross borders of ethical behaviour and teacher's personal responsibility and form social requirements for educators as a whole professional group. An example of this kind of code can be the International Code of Ethics for Educators (Whitehead & Mc Farren Aviles, 2018), which is divided into four , which promotes the use of teacher ethical codes and combats corruption and fraud in education. It can be also useful for the field of adult education and learning. Given the fact that the profession of a teacher and the profession of an adult educator are very close in their focus on education, in some countries (for example in Australia) codes do not distinguish these professional groups neither in their names nor in their focus.
Forster (2012) analysed eight codes from states and territories in Australia focusing on their purpose, structure, content and explicit requirements for the practical educational activity. As for the purpose, the author discovered that it can be formulated as a statement of ethical commitments, practices and aspirations, as a wide framework for decisionmaking or common understanding and a disciplinary tool or means of compliance. As for the extent, many codes are one-page statements about values, for example in South Australia and New South Wales, which are grouped into the following categories: integrity, dignity, responsibility, respect, justice, care. As for the form, codes can be inspiring, shifting teachers' role and turning teachers into moral heroes, and on the other hand, regulating, having the need to monitor and discipline teachers. When researching teacher codes, van Nuland (2009) sees its basis in defining the role of teachers and in description of the good teacher. He provides examples from international and state documents which argue the need for codes and purpose or function of codes. He states that in the preamble, codes identically emphasise that their purpose is to ensure the protection of a client, it means of the child by the teacher. The main elements of codes are considered to be universal moral principles, which were determined by a range of research quite identically.
Codes as a result of collective conscience of a profession can have three basic formats, they are a) regulatory documents, with specific advice to address and behaviour, often with a system of sanctions, b) widely phrased creeds often stating aims, objectives and values, with no specific guidance content and often encompassed in a larger document and c) elaborate codes covering social responsibility among the many stakeholders as well as a wide range of topics (Frankel, 1989;Farrell & Cobbin, 2002as cited in van Nuland, 2009). The author also listed activities undertaken to promote the code of conduct, such as newsletters, brochures, websites, teacher hotline to respond to teachers' concerns and issues, presentations at university faculties, outlining the code, email box to receive and respond to requests, and seminars for teachers, representatives from education unions, teacher educators, teacher employers and school council, groups. The issue of codes of conduct for school teachers was the subject of an analyticalcomparative study by Golubeva and Kaninš (2017). They found out that codes can be found in many countries. Some countries have a lot of experience in implementing these codes. In other countries, such codes are still a relative novelty. Codes differ in their level of detail, degree of reliance on sanctions, and the extent of the profession's involvement in their development, implementation and review. Codes as an expression of the profession's values and principles can strengthen the ethics of the teaching profession and improve the quality of teaching and the education experience for students and their parents. Codes are also regulatory tools that prescribe standards of conduct often backed by legally established sanctions, inquiry and investigation procedures, and monitoring and enforcement bodies. The authors also pointed out challenges and gaps in the development and dissemination of a code: a code not embedded in professional culture, lack of ownership, lack of a clear implementation framework and rules without aspirational value statement.
We cannot disregard the fact that it is also possible to raise arguments against codification of ethics. They can be based on knowledge why codes do not work in practice (Gilman, 2005, p. 63-67). It is because the codes raise unrealistic expectations, codes coexist together with a large number of legal norms and are adopted from another professional field or because they get old. Old codes become irrelevant because of the dynamics in governments and organizations. Other specific reasons against the codification of ethical requirements for adult educators can be concerns about the bureaucratisation and restrictions on the freedom of adult educators' work, concerns about unjustified interventions in the commercial environment in the field of adult education and doubts regarding the enforceability of rules of ethical codes and banal sanctions for their violation. Doubts regarding the need for ethical codes can be also observed in the study by van Nuland (2009, p. 83), which after a review of literature on teacher codes that was available at the time of research states that 'there is no objective evidence about the extent to which codes have impact on individual teacher's behaviour'. On the other hand, it is possible to observe at least some attempts to identify 'factors determining the impact of a code that include: a) stakeholder involvement in the development of the code, b) the integration of dissemination activities into the education, training and professional review of teachers, c) the organisation of practical workshops and seminars for teachers, and d) the involvement of the professional bodies responsible for the code' (Golubeva & Kaninš, 2017, p. 5).

Analysis of selected ethical codes for adult educators
An analysis of real, functioning codes (process codes) can be useful for at least three reasons. Firstly, it can help (inter)national organisations associating general or a specific group of adult educators monitor the development of ethical requirements for adult educators' performance or educational services of their providers in other countries, which in its nature represents a useful benchmarking. At the same time, it enables them to compare the aims, form and content of codes with regards to the (inter)national education policy and its implementation strategies. Secondly, it can serve as a suitable framework for shaping professional competences and values of adult educators, whether they are certified lecturers or graduate andragologists. Thirdly, it can be useful for learners since it will provide them with a good picture of the educational institution or the educator and it can help overcome barriers preventing adults from learning, often stemming from uncertainty or the lack of information about the educational process or attitude to learners. Ethical codes in accordance with Siegel's (2002) requirement often state educators' intention to actively include learners in the instruction. This could increase the number of students with offensive behaviour and decrease the number of students with defensive behaviour in the instructed group. The former ones have an active attitude to learning, they prefer activating methods, they independently search for information and broaden their knowledge and they want to learn more. Individuals from the latter group can be characterised as observers of the lesson, preferring teachers to present the learning content and only using information provided by them, abandoning learning and plans for further education when they have difficulties (Skibińska, 2001;Frąckowiak, 2009).
[206] Malach The aim of the comparative analysis was: • To find common structural and content features in ethical codes of a wide range of andragogical professions • To identify unusual, non-standard regulations or principles of codes, which can encourage reflection on the innovation and modification of ethical codes in andragogical educational associations and organisations • To identify measures aiming for the compliance with codes by members and staff of educational associations or organisations.

The research sample of ethical codes and codes of practice
The research sample of ethical codes or codes of practice consisted of 26 codes. The sample was gathered by searching for codes using keywords in four languages -English, Polish, Czech and Slovak. The selection was chosen with regards to author's language skills. No countries (nor continents) from which codes for the analysis were chosen were determined beforehand. Searching for codes using English keywords resulted in finding codes from Europe, North America, Australia and New Zealand. All codes that were available in Czech, Slovak, Polish and English were analyzed. At the same time, I wanted the sample to include codes from national associations of lecturers, tutors, coaches or advisors as typical andragogical sub-professions and also teachers or tutoring professions indicating how broadly they are understood in the area of lifelong learning. The significant territorial span of codes used and their focus on various andragogical subprofessions can be viewed as an effort to make the sample of analysed codes more representative.
Keywords were put together usually consisting of three parts (ordered by the languages): 1. code, kodeks, kodex, kódex/standard, standard, standard, standard 2. ethics, etyki, etický, etický/practice, postepowanie, praxe, prax 3. adult educator/tutor/advisor/teacher/coach/mentor; edukator/tutor/doradca/nauczyciel/trener/mentor; lektor/tutor/poradce/kouč/mentor; lektor/tútor/poradca/kouč/mentor Approximately one-third of the codes analysed was from the Czech Republic (30.7%), 4 of them were from USA and Poland, 3 of them were from United Kingdom and Australia and the rest was from Slovakia, New Zealand and Canada (Table 1). More than half of the codes-14 (53.8%) were published in the last three years (2016-2018), 7 codes (26.9%) in the years 2013-2015 and 5 codes (19.2%) are older than 5 years. Codes without the date of publication were assigned 2018, since they were accessed in this year on their websites. Codes were usually found on websites of associations and organisations in the section called 'About Us' and therefore, it can be assumed that they regard this information as essential for the members as well as for the clients.

Structural and content analysis of ethical codes
Structured codes are those whose content is divided into parts with a title and usually a number, where parts called Preamble or introductory sentences expressing the purpose or goals of the code are generally not numbered. Unstructured codes usually have only (sometimes numbered) a list of ethical principles for lecturers' performance (about 10 to 24). The majority (22) of codes (84.6%) is structured. Based on the analysis, it is possible to determine these structural parts of codes which are (completely or largely) included in a greater number of codes.
1. Preamble 2. Terminology 3. Values or ethical principles of the association/organisation 4. Relationship towards the learner, client, candidates (external links) 5. Attitude (responsibility) to lecturer's profession, other educators, association or organisation (internal ties) 6. Confidentiality/protection of personal data and information gathered during education 7. Compliance with the code, sanctions Unstructured codes are usually one-page long. Structured codes have about two to seven pages. Several codes are more extensive, code number 3 (5 pages), code number 4, 12, 13 (6 pages), code number 20 and 21 (7 pages) and the largest is number 26 (20 pages).
[208] Malach The Preamble or introductory sentences of codes mainly contain a declaration of the purpose or aims of the code, where the following ones prevail: • Definition of duties of association/organisation members, which will ensure its good name • Reference to association/organisation visions and missions • Determining the expected conduct of the member both within the association as well as towards the outside • Ensuring the best professional performance or best practice possible • Ensuring that ethical standards/principles are respected • Determining and maintaining the benchmark for education and educational services If codes mention ethical principles or requirements for lecturers' ethical behaviour, they are mainly: integrity, confidentiality/discretion, irreproachability, honesty, confidence, humanity, tolerance, professional and social responsibility, dignity, esteem/respect for learners' cultural background, values and needs, politeness, justice, enthusiasm, sensitivity, reliability, prudence, anti-discrimination, patience, flexibility, welfare and rights of clients.
Codes also contain requirements for lecturers' professionalism in the andragogical or androdidactic sense more frequently than ethical requirements. Frequent requirements are: being aware of one's role and responsibility; using a range of modern methods; using media/technology responsibly and ethically and preventing teachers and learners' plagiarism; always transferring current, relevant and true information; striving for open and partner communication; providing feedback and evaluation at the right time; enabling learners to share responsibility for their learning, evaluation, goal setting; striving for the highest quality of work; ensuring learners' progress during instruction; demonstrating self-reliance, active and proactive approach; delivering reliable (research) data and sources to learners; improving one's knowledge and skills, also based on clients' feedback; being capable of self-management, self-evaluation and self-control; being able to work in a team; using only truthful promotion. Members will quote authors of texts and materials and will not claim them to be their own. They will avoid any emotional or sexual relationship with current clients. A coach acquaints clients with the code.
Not given specifically, but it is said in the preamble: If a member of the organisation did not comply with the requirements and instructions when working with clients, the Ethical code would be used as a basis for dealing with complaints or disciplinary proceedings. Every ÁMOS agency employee and associate working as a lecturer is obliged to report suspected breaches of provisions of the Ethical code or other generally accepted ethical standards by another employee or associate working as a lecturer.
When investigating breaches of the rules of conduct enshrined in the Ethical code or other ethical standards, the management proceeds in accordance with the applicable law and always uses common sense.
1. Every employee and associate working as a lecturer is obliged to report suspected breaches of provisions of the Ethical code or other generally accepted ethical standards if they have a justified reason.
The compliance with the code is monitored by the company management and they also deal with possible charges concerning its breaches.
When investigating the cases of breaching the rules of conduct enshrined in the Ethical code or other ethical standards from the field of adult education, the company management proceeds in accordance with the applicable law and always uses common sense.

Resolution of Ethical Issues and Violations
The standard includes provisions during the implementation of research and evaluation. It ensures that research is carried out with participants' consent, it uses appropriate methods for a data collection, protection and interpretation and it ensure the responsibility for publishing its results.
The standard also deals with issues regarding advertising and public statements and publication of work in compliance with privacy, anonymity and confidentiality.
HRD professionals seek to ensure that their programs, or those in which they participate, are competently designed and developed, provide proper exchanges and experience during implementation, meet the requirements of the objectives set by the program, and are accurately evaluated.
Dealing with ethical problems and violation of rules is included but sanctions are not defined.

Identification of non-standard provisions in codes
The analysis of ethical codes/codes of practice also provided information about less common or (until now) non-standard provisions (Table 2). Non-standard provisions are considered to be those which appeared only exceptionally, it means in one or a few codes. They have or can have an innovation potential for ethical codes of adult educators in general or for their subgroup (for example coaches or advisors).
[212] Malach Unusual provisions were found in 25 codes (96.1%) and they can be grouped into these areas: • Members of the association ensure that the price of education is adequate.
• Lecturers respect the voluntary nature of learners' participation in roles.
• Lecturers avoid sexual relations with the learner. 3x • Lecturers quote authors of texts and materials.
• Lecturers ensure that they are dressed appropriately and maintain company reputation. • Lecturers are obliged to report suspected breaches of the code. 2x • The executive staff of the organisation is obliged to manage the team and represent the organisation. • Realising one's needs, motives and prejudices so that they do not influence one's work. • Using technologies in an ethical way.
• Enabling students to share responsibility for their learning.
• Thinking critically about their own educational assumptions, values and practice in the context of the changing world. • The code contributes to students' education, welfare and wellbeing or to their best interest and development of their unique potential. 3x • Lecturers cannot know answers to all questions.
• Lecturers adjust their approach to teaching according to learners' learning styles, preferences and interests. 2x • Lecturers' obligations in online teaching.
• Lecturers and the organisation do not use misleading advertisement and marketing practices. • Organisations have to ensure curricular and methodological education and annual evaluation of its tutors. • Lecturers are obliged to retain worldview impartiality.
• Lecturers are obliged to help and support one another and also to protect one another against mobbing and isolation. • Human Resource Development (HRD) professionals undertake training or instruction in the use of techniques or procedures that require certification, licensure, or expertise only if they possess the appropriate prerequisite preparation.
The less frequent provisions found in codes react to emerging social problems in the area of sexual relationships, work relationships, understanding of learner's role, technological development, protection of copyright and concept of the quality of life. Specialised standards or codes could be used; for instance a safe Internet usage, professional ethics, advertisement and marketing ethics, copyright law and others.

Code measures aiming to their compliance by the members of educational associations or employees of organisations
A preliminary analysis of codes suggested that they do not or very rarely deal with situations of disrespecting or violating the principles of the code by an adult educator. To analyse these situations, it is desirable to use the theory of law, which, however, cannot be completely applied to ethical codes as subjects of an examination. Nonetheless, their prevailing structure, where association/organisation values in form of ethical principles represent only one of the significant parts of codes, in addition to other parts dealing with the relationship towards learners, clients, prospective clients (external ties) and also the attitude to the profession of a lecturer, other educators, association or organisation (internal ties). These two parts are in a very close connection with labour law, and that is why legal constructs can be used for the examination of codes. Legal theory deals with legal norms which are the smallest, indivisible (atomic) component of a legal order containing one particular command, prohibition or legal permission. A legal norm can consist of three essential parts: hypothesis, disposition and sanction (Knapp, 1995). The hypothesis establishes conditions under which a certain rule of conduct should be carried out. Therefore, it is a criterion for assessing whether a certain rule will be applied to a given case. The disposition is a core of a legal norm and it establishes the rule of conduct itself. It establishes desirable (or undesirable) act. The sanction defines legal consequences for the violation of the rule given in the disposition. In certain generally applicable norms, no hypotheses are defined and vice versa, others (for instance the Constitution) do not provide sanctions. Legal norms which do not provide sanctions are sometimes called imperfect (lex imperfecta in Latin). When examining individual rules (dispositions) of ethical codes, the definition of a hypothesis cannot be always expected since it can be usually derived from the name of the organisation issuing the ethical code. The hypothesis supposes that an adult educator acts as a member of a certain andragogical subprofession (for example as a couch) or is a registered member of a professional association or employee of an education provider. Ethical codes, contrary to legal norms, do not usually define sanctions for the violation of a particular rule, but for disrespecting the ethical code as a whole. Sections dealing with measures or sanctions for violating the ethical code, or the code of practice, were found in almost half of the codes (12 in total, 46.1%, see Table 2). Some codes contain several sanctions. According to their nature and impact on the educator, they can be put into the following groups: • Expulsion from the association/revocation of the membership. 5x • Suspension of the membership in the association.
• Warning or convicting members for their behaviour.
• Loss/revocation of the certification issued by the association. 3x • Dealing with complaints with the option of using disciplinary proceedings.
• Dealing with complaints with the option of using applicable legal norms and common sense. 2x • Using labour and legal norms.
• Prohibiting the use of the organisation logo.
• Self-assessment using a tools list of professional standards.
• Withdrawing literature, materials and programmes disrespecting code standards.
The expulsion of members from the professional association, suspension of their membership or warning or (moral) conviction was mentioned in seven codes. The second most frequent sanction is the loss or revocation of the certification. Prohibiting the use of a logo or withdrawing advertisement (probably linked to the membership in the association) is used by three associations and three educational organisations refer to [214] Malach applicable law when dealing with a violation of the code. An interesting option, which can (but does not have to) have a nature of an ethical sanction, is educator's (self-)reflection using the offered evaluation tool (see The self-assessment tool of Education and Training foundations, UK -in Table 2, number 15). Other useful tools could be outputs of VINEPAC (Validation of informal and non-formal psychopedagogical competencies of adult educators) project (2008) in the form of Validpack, which was later tested by a subsequent CAPIVAL (Capitalizing on Validpack) project (2012), or AGADE project (Jääger & Irons, 2006). Standards on Ethics and Integrity (AHRD, no. 26 in Table 2) even state that AHRD professionals cooperate in ethics investigations, proceedings, and the resulting activities of any professional organization involved with performance improvement, training, instruction, or learning, when deemed appropriate and reasonable. In so doing, they make efforts to help resolve any issue related to possible violations of ethics.

Discussion
No other study has been found in the andragogical literature which would focus on the examination of ethical codes for adult educators. However, there are numerous studies on teacher codes more generally and in relation to teachers in school which the results of this study could be related to. However, as the focus of this study was on finding common content and formal features across ethical codes, the discussion does not focus on implementation, an issue that is commonly discussed in previous research. For this reason, it is possible to view and compare these results only in certain areas.
From the owner's point of view, or code creator's, codes for adult educators are mainly created by professional associations, while codes for teachers by government authorities (Golubeva & Kaninš, 2017). As for the number of mentioned ethical principles or requirements for lecturers' ethical behaviour, more principles (up to 21) were found in codes for adult educators than in codes for teachers. Golubeva and Kaninš (2017) identified 12 principles in 12 codes in European countries or their parts, however this number was found only in one code (Catalonia), although Poisson (2009) offers a list of 22 major values to be considered within a code. When a regulation in codes for adult educators is disrespected, there are up to 12 penalties, which are very diverse, most frequently the lecturer loses membership in the association or their lecturer certificates, which can result in not being practically able to perform any lecturer activity. Breaching the principles in codes for teachers can have greater consequences for the teacher, often it can mean the loss of a job. Most codes for teachers do not state particular penalties. However, they are stated in half of all analysed codes for adult educators.
Code of ethics for adult educators declare lecturer's responsibility (or obligation) towards participants of an educational event or towards their employer. This is different compared to codes for teachers which rather declare teacher's responsibility towards a wider community of stakeholders, not only including students but also their parents or legal representatives, representatives from the local government, central state government, and global communities. Codes of ethics for adult educators are more often structured according to ethical principles, as opposed to codes of ethics for teachers which are more often structured according to a list of stakeholders towards whom the teacher has ethical obligations.
The research presented in this article did not formulate a specific hypothesis. Rather, the analysis provides a descriptive account of the use of ethical codes in a limited number of geographical locations. However, despite the limited scope of data, the results presented here could provide a starting point for further research discussion, as well as discussion and debate among different stakeholders involved in the education of adults.

Conclusion
Based on the results presented here, I argue that ethical codes and codes of practice play a significant role in creating a professional culture of adult educators. They are, together with other five standards -professional, qualification, education, evaluation and selfevaluation -essential documents. These documents are the basis for, and interreact with, the emerging andragogical subdiscipline, andragogical profesiology (Malach, 2014). Ethical codes promote visions, goals and values of an educational association or organisation, define constructs they work with, describe the relationship between educators and clients (their external functions) as well as the relationship with other educators, an association/organisation, ensure the protection of information connected with the educational process and inform members and the public that a violation of the code would be investigated and sanctioned. The content of analysed codes illustrates that their creators see changes in external conditions for the work of adult educators and the development of educational means (technologies, strategies) and react to them by formulating new recommendations or prohibitions. It is interesting to note that half of the codes declare that they are ready to deal with educators' ethical failings or explicitly formulate sanctions for this failing.
The contribution of this study can also be seen in the fact that it enriches the andragogical theory with knowledge of the purpose and functions of ethical codes and their structural elements and their current content. For education policy, ethical codes can represent a tool for monitoring the education market in the competitive environment aiming to ensure quality, efficacy and client-friendliness. If a provider of educational services for adults has a declaration of ethical rules, it can be viewed as a competitive advantage by their clients. Motivation for respecting code standards and requirements can be also seen in acquiring and maintaining a good reputation by the lecturer as a member of an association, association of certified lecturers or educational organisation. Familiarisation with the content of ethical codes from associations, organisations or lecturer (sub)professions and their practical application should be an essential part of certification courses for educators and graduate studies of andragogy. This content and formal analysis of codes of ethics for adult educators can be an inspiration for further research focusing on the issue of the implementation of codes and their impact on education practice.