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The reputation of our brands is based on the editorial independence, integrity and high journalistic standards of our output. The rules set out here are intended to apply to all our platforms (print, digital and broadcast), unless it is stated otherwise.  You must follow these rules even when they set a ‘higher bar’ than other external regulations unless you have specific approval to the contrary from a senior executive. In addition to this Code, you must adhere to the general law and any other external regulations as required by the Group. Many staff will work primarily for one company within the Group.  Managers should be aware, therefore, that individuals may require advice and guidance on regulatory questions if they are contributing to a platform that is outside their usual sphere of operations.
If you have any queries about relevant regulations or legal matters, please contact the managing editor’s office or legal department as appropriate.
You must fully cooperate with the editors in the area you are working in or for, and undertake whatever pre-publication checks and research are requested by those editors or by the companies’ legal advisers or other relevant executives. Always seek advice about any specific issues you are not sure about.  Also, be mindful of the need to remain up to date with all information provided on legal and compliance subjects, and make sure you familiarise yourself with legal bulletins and notices sent out by your department heads, by the companies’ legal advisers, the managing editor’s office or by other senior executives.
It is your duty to raise, in a full and frank manner and making full disclosure, any issues that could have a bearing on whether publication of any material you are involved in complies with all legal and regulatory requirements, as well as any issues to do with staff conduct.
If in doubt about regulatory matters please contact your line manager or the managing editor’s office. In the course of your work you will speak to a great many people.  Except in exceptional circumstances (see below), you should be up front about the fact you are a journalist and you must always identify who you are and who you work for when asked, unless there are public interest reasons for not doing so.
The same rules apply when contacting somebody via email, Facebook or Twitter that apply in relation to face-to-face meetings and phone conversations.
If a source needs to remain confidential you should ensure that they cannot be identified – directly or indirectly - from your notes, or any data on your mobile phone or other device. You should be cautious how you use the internet or social media to obtain material for a story, both in terms of trustworthiness of the information or identification, and also the rights in the material (eg copyright).
From the point of view of rights ownership, you should bear in mind that what you see online, including on social media, is not free for use just because it is free to view.  So, not only must you consider questions of accuracy and privacy, you should also assess whether material can lawfully be reproduced or even drawn on without the consent of the rights holder and whether re-use of that material may carry a fee. If in doubt, ask a child how old they are and get confirmation if you are still uncertain.  The onus is on you to establish an accurate age.


If you have any uncertainty about the public interest requirements or any other matter, do talk to your department head and then, as appropriate, the managing editor’s office, the Group’s legal advisers or another senior executive.
It is not only good, responsible journalism but also a keystone of how we might defend a libel complaint, that any potentially critical or damaging reference is put to the subject before publication.
Contributors, especially to broadcast material, should be informed of the wider context within which their comments will be placed and – where applicable – be told about who else may be contributing to the same programme or article.
You should where possible make detailed notes or keep other contemporaneous records of pre-publication conversations or exchanges, and these should be retained, bearing in mind that you may have to produce them as evidence in court. If you have obtained material from the internet it is important that you retain copies of relevant pages, tweets, pictures or posts.  Since information can easily be taken offline, you should take screen-grabs of any material that could be contentious or disputed.
When commissioning material from a freelance individual or entity, for example an outside investigative company, you should take steps to consider whether their track-record suggests they are professional, reliable and trustworthy. If you are in any doubt, refer the issue to your department head.  Any freelance you intend to use should be directed to this Code of Conduct and to the Terms for Freelance Contributions on the Group’s websites with which they are required to comply. Crucially, you must be aware that any payment to a police officer or public official will breach the law without exemption.
Anyone engaging in any form of deception for journalistic purposes (and this includes where they do not make it clear they are a journalist when making enquiries) should seek approval in advance by completing an Approval Form.  It is important that this happens at an early stage in order that a proper record of the decision-making process is made which can be produced subsequently if necessary. The form should be completed after discussion with your department head and the managing editor’s office, if possible before you embark on any sort of undercover investigation, no matter how apparently insubstantial.  Failure to get advance approval could lead to non-compliance with the company’s Code or a tainting of crucial legal evidence.
If you genuinely did not have an opportunity to seek approval in advance, or an external journalist or entity has come to us with evidence obtained through subterfuge, you must refer it urgently to your department head and the managing editor’s office so that the situation can be properly assessed.
You should be transparent about any outside political, philosophical, religious or financial interests that might conflict with your journalistic independence or integrity, or could be perceived to do so. If anyone writing about financial information is concerned about a potential conflict of interest, they must raise their concerns immediately with their department head.  There are special rules for those working on business and city desks whereby journalists must ensure that an accurate and updated record is kept by their desk head or the managing editor’s office of all relevant investments and interests. It is our primary endeavour to publish information that is accurate and will not mislead readers.  You must take care not to distort information either by disingenuous phrasing or by omission.
If you think that material has been published or broadcast that is wrong, you should notify your line manager and the managing editor’s office.  It may be necessary to take corrective action but you should not generally proceed without discussion.
TV news and other programmes that might be considered to fall into the ‘current affairs’ bracket are subject to rules governing impartiality.  The Ofcom Code sets out those rules in full. If quoting someone directly, you should generally use their exact words.  If you do not want to use the way they have expressed something then, if it is editorially justified, you should not quote directly but paraphrase their words in indirect speech, taking care not to change the actual meaning.


You should exercise caution if you want to quote someone anonymously.  Ask yourself what their motivation is if they are not prepared to go on the record, and whether an improper purpose could taint their reliability as a source (and thus make defending our published or broadcast material more difficult).
In order to ensure the integrity and independence of our editorial content we should not offer copy or picture approval to any subject.  If this is the only way to secure an interview, approval must be sought in advance from your desk head or relevant senior executives. There are no specific rules regarding the presentation of information about drugs, tobacco or alcohol insofar as newspapers’ editorial content is concerned.  However, the Ofcom Code makes clear that care should be taken not to glamorise on television the taking of such substances unless there is editorial justification (primarily in order to protect children). If material is well-established in the public domain, that may over-ride the usual privacy protections.  However, you must not work on the premise that, because you can access a picture publicly, it is therefore automatically safe for use. You must also be particularly careful not to do anything which could amount to taking advantage of vulnerable adults, which means those who are or may be in need of care services by reason of ‘mental or other disability, age or illness’ and who may be unable to protect themselves against ‘significant harm or exploitation’.  If you are entering a non-public area of a hospital (or similar institution) you will need to obtain permission from a senior executive of the hospital, unless there is a public interest justification for not doing so. Remember that a person’s right to privacy is not automatically lost simply because material about them has circulated online to some degree. If you have concerns about the conduct of another social media user towards you, please raise it immediately with your department head and, if appropriate, the managing editor’s office. It is the responsibility of every department head, but also everyone working for the Group, whatever their status, to ensure that you follow up anything that might appear to you to be incorrect, even to a minor extent, or which raises any alarm bells from a legal or editorial point of view - whether or not you yourself are responsible for that material.  You should pass any concerns to the managing editor’s office or the Group’s legal advisers as appropriate. Click here to view instructions on how to disable your ad blocker, and help us to keep providing you with free-thinking journalism - for free.
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