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Code of Conduct

The Code

The Code – including this preamble and the public interest exceptions below – sets the framework for the highest professional standards that members of the press of Global Ground Media have undertaken to maintain. It is the cornerstone of the system of voluntary self-regulation to which they have made a binding contractual commitment. It balances both the rights of the individual and the public’s right to know.

To achieve that balance, it is essential that an agreed Code be honoured not only to the letter, but in the full spirit. It should be interpreted neither so narrowly as to compromise its commitment to respect the rights of the individual, nor so broadly that it infringes the fundamental right to freedom of expression – such as to inform, to be partisan, to challenge, shock, be satirical and to entertain – or prevents publication in the public interest.

It is the responsibility of Global Ground Media to apply the Code to editorial material in both printed and online versions of publications. We take care to ensure it is observed rigorously by all editorial staff, freelancers and external contributors, including non-journalists.

Global Ground Media also maintains in-house procedures to resolve complaints swiftly. Please refer to the Complaint Procedure for more information.

1. General Accuracy

i) Global Ground Media takes care not to publish inaccurate, misleading or distorted information or images, including headlines not supported by the text.

ii) A significant inaccuracy, misleading statement or distortion must be corrected, promptly and with due prominence, and — where appropriate — an apology published. Our up-to-date Retraction Policy is made available to the public via our website.

iii) A fair opportunity to reply to significant inaccuracies should be given, when reasonably called for.

iv) Global Ground Media, while free to editorialise and campaign, must distinguish clearly between comment, conjecture and fact.

v) A publication must report fairly and accurately the outcome of an action for defamation to which it has been a party, unless an agreed settlement states otherwise, or an agreed statement is published.

2. Accuracy of Sources

i) Global Ground Media ensures accuracy of sources. To that end we require the use of first-hand sources, double-checking of facts, validation of material submitted, confirmation via two reliable sources and corroboration of any claims or allegations made.

ii) Contributors are required to keep a record of notes, recordings, bookmarks and email correspondence relating to the stories. However, where anonymity has been requested or where it is essential, we make sure that our records do not identify those who have been interviewed.

3. Contributors

i) All staff, freelance and external contributors must adhere to this Code of Conduct.

ii) Due diligence is done for any freelance contributors to see whether their track-record suggests they are professional, reliable and trustworthy.

4. Third Party Material

i) Contractual warranties are signed with all contributors regarding originality of sources, information and all other material they provide.

ii) When material by others is used, Global Ground Media always check whether it is allowed to be used in the first place. If it is, we attribute and link that material to the original source in all cases. Examples are data of research institutes or previous reports by other media outlets.

iii) When appropriate, we state there is a margin of error with regard to information provided by others and our analysis.

5. *Privacy

i) Everyone is entitled to respect for his or her private and family life, home, health and correspondence, including digital communications.

ii) Global Ground Media is expected to justify intrusions into any individual’s private life without consent. In considering an individual’s reasonable expectation of privacy, account will be taken of the complainant’s own public disclosures of information and the extent to which the material complained about is already in the public domain or will become so.

iii) It is unacceptable to photograph individuals, without their consent, in public or private places where there is a reasonable expectation of privacy.

6. *Harassment

i) Global Ground Media contributors do not engage in intimidation, harassment or persistent pursuit.

ii) We do not persist in questioning, telephoning, pursuing or photographing individuals once asked to desist; nor remain on property when asked to leave and must not follow them. If requested, we have to identify ourselves and who we represent.

iii)  We ensure these principles are observed by those working for us and take care not to use non-compliant material from other sources.

7. Intrusion into grief or shock

In cases involving personal grief or shock, enquiries and approaches must be made with sympathy and discretion, and publication handled sensitively. These provisions should not restrict the right to report legal proceedings.

8. *Reporting Suicide

When reporting suicide, to prevent simulative acts care should be taken to avoid excessive detail of the method used, while taking into account the media’s right to report legal proceedings.

9. *Children

i) All pupils should be free to complete their time at school without unnecessary intrusion.

ii) They must not be approached or photographed at school without permission of the school authorities.

iii) Children under 16 won’t be interviewed or photographed on issues involving their own or another child’s welfare unless a custodial parent or similarly responsible adult consents.

iv) Children under 16 won’t be paid for material involving their welfare, nor parents or guardians for material about their children or wards, unless it is clearly in the child’s interest.

v) We do not use the fame, notoriety or position of a parent or guardian as sole justification for publishing details of a child’s private life.

10. *Children in sex cases

Global Ground Media will not, even if legally free to do so, identify children under 16 who are victims or witnesses in cases involving sex offences.

In any press report of a case involving a sexual offence against a child:

i) The child must not be identified.

ii) The adult may be identified.

iii) The word “incest” must not be used where a child victim might be identified.

iv) Care must be taken that nothing in the report implies the relationship between the accused and the child.

11. *Hospitals

i) Global Ground Media must identify themselves and obtain permission from a responsible executive before entering non-public areas of hospitals or similar institutions to pursue enquiries.

ii) The restrictions on intruding into privacy are particularly relevant to enquiries about individuals in hospitals or similar institutions.

12. *Reporting of Crime

i) Relatives or friends of persons convicted or accused of crime should not generally be identified without their consent, unless they are genuinely relevant to the story.

ii) Particular regard should be paid to the potentially vulnerable position of children under the age of 18 who witness, or are victims of, crime. This should not restrict the right to report legal proceedings.

iii) Global Ground Media generally avoids naming children under the age of 18 after arrest for a criminal offence but before they appear in a youth court unless they can show that the individual’s name is already in the public domain, or that the individual (or, if they are under 16, a custodial parent or similarly responsible adult) has given their consent. This does not restrict the right to name juveniles who appear in a crown court, or whose anonymity is lifted.

13. *Clandestine devices and subterfuge

i) Global Ground Media will not seek to obtain or publish material acquired by using hidden cameras or clandestine listening devices; or by intercepting private or mobile telephone calls, messages or emails; or by the unauthorised removal of documents or photographs; or by accessing digitally-held information without consent.

ii) Engaging in misrepresentation or subterfuge, including by agents or intermediaries, can generally be justified only in the public interest and then only when the material cannot be obtained by other means.

14. Victims of sexual assault

Global Ground Media will not identify or publish material likely to lead to the identification of a victim of sexual assault unless there is adequate justification and they are legally free to do so.

15. Discrimination

i) Global Ground Media avoids prejudicial or pejorative reference to an individual’s, race, colour, religion, sex, gender identity, sexual orientation or to any physical or mental illness or disability.

ii) Details of an individual’s race, colour, religion, gender identity, sexual orientation, physical or mental illness or disability must be avoided unless genuinely relevant to the story.

16. Financial journalism

i) Even where the law does not prohibit it, Global Ground Media will not use for their own profit financial information they receive in advance of its general publication, nor should they pass such information to others.

ii) They must not write about shares or securities in whose performance they know that they or their close families have a significant financial interest without disclosing the interest to the editor or financial editor.

iii) They must not buy or sell, either directly or through nominees or agents, shares or securities about which they have written recently or about which they intend to write in the near future.

17. Confidential sources

i) Global Ground Media has a moral obligation to protect confidential sources of information.

ii) Global Ground Media might agree to any of the following to disguise identity when appropriate: using a voice-over, using blurred images, hiding locations, avoiding using real names and/or not giving an age range.

iii) If dealing with an anonymous source who is making serious allegations Global Ground Media assesses whether:

  • the story is of significant public interest;
  • the source is credible and reliable;
  • the source is likely to be in a position to offer accurate information;
  • there are any legal issues – in consultation with a professional Media Lawyer;
  • anyone’s safety could be at risk;
  • a response to the allegations can be found.

iv) In case an identity is disguised we always state clearly that we do so and why.

18. Witness payments in criminal trials

i) No payment or offer of payment to a witness – or any person who may reasonably be expected to be called as a witness – should be made. This prohibition lasts until the suspect has been freed unconditionally by police without charge or bail or the proceedings are otherwise discontinued; or has entered a guilty plea to the court; or, in the event of a not guilty plea, the court has announced its verdict.

19. Payment to criminals

i) Payment or offers of payment for stories, pictures or information, which seek to exploit a particular crime or to glorify or glamorise crime in general, must not be made directly or via agents to convicted or confessed criminals or to their associates – who may include family, friends and colleagues. 

The Public Interest

There may be exceptions to the clauses marked * where they can be demonstrated to be in the public interest.

  1. The public interest includes, but is not confined to:
  • Detecting or exposing crime, or the threat of crime, or serious impropriety.
  • Protecting public health or safety.
  • Protecting the public from being misled by an action or statement of an individual or organisation.
  • Disclosing a person or organisation’s failure or likely failure to comply with any obligation to which they are subject.
  • Disclosing a miscarriage of justice.
  • Raising or contributing to a matter of public debate, including serious cases of impropriety, unethical conduct or incompetence concerning the public.
  • Disclosing concealment, or likely concealment, of any of the above.
  1. There is a public interest in freedom of expression itself.
  2. The regulator will consider the extent to which material is already in the public domain or will become so.
  3. Editors invoking the public interest will need to demonstrate that they reasonably believed publication – or journalistic activity taken with a view to publication – would both serve, and be proportionate to, the public interest and explain how they reached that decision at the time.
  4. An exceptional public interest would need to be demonstrated to override the normally paramount interests of children under 16.

A note on photographs

Clause 1 (General Accuracy) prohibits the publication of inaccurate, misleading or distorted material which includes pictures.

Clause 5 (Privacy) of the Code relates generally to respect for private and family life, home, health and correspondence and states that it is unacceptable to photograph individuals in private places without their consent.

Clause 6 (Harassment) states that Global Ground Media journalists and photographers must neither obtain nor seek to obtain information or pictures through intimidation, harassment or persistent pursuit.

The Clauses that seek to protect vulnerable groups of people – in particular those relating to children (Clause 9 and 10) and hospitals (Clause 11) – include provisions on the actions of photographers as well as reporters, as does Clause 13 (Clandestine devices and subterfuge).

Version: May 2018


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