Code of Conduct & Complaints

It is important to us that we get things right.  Our commitment to high standards is embodied in our company Code of Conduct, which is set out in full below.  This Code applies to all members of our editorial staff, as well as freelancers who work for us, and our business partners.

Adherence to our in-house Code requires that our journalists also abide by the terms of the industry-wide Code of Practice, which is overseen by the Press Complaints Commission.  We take any complaint to the PCC seriously.  More information is available at .

We prefer, however, to deal with any complaints directly – not least because it can save time.  For any complaints about editorial material  – either in print or online – or about our staff please in the first instance fill in the Complaints Form, link below.  If you have any queries about the complaints process please email the office of the managing editor by email (

Queries about promotions should be addressed to

Information about advertising can be found at .

You can also contact us by telephone on 020 3367 7000 or in writing: London Evening Standard, Northcliffe House, 2 Derry Street, Kensington, London W8 5TT.

Please  click here for our online complaint form. We will endeavour to respond to all complaints submitted in this way, provided they are genuine and do not contain offensive language.

Code of Conduct



The reputation of our newspapers and websites, in the UK and around the world, is based on our editorial independence and integrity. Our readers, advertisers and business partners must be able to trust us, confident that our editorial and commercial decisions and procedures are ethical and beyond reproach.

This Code provides clear standards on the levels of behaviour and conduct which should underpin how we work. It applies to all board members, employees, temporary or shift workers, contractors, agents, consultants and people acting for on or behalf of the Company (1) . All editorial contributors, whether contracted or freelance, are expected to comply with our approach as set out in this Code, and their particular attention should be given to the Editorial Provisions below. Where a provision only affects employees that will be made clear.

While managers should ensure this Code is understood within their own areas, everyone takes personal responsibility for their own compliance.

It is impossible to spell out every ethical scenario that could arise so you need to use your good judgement to uphold the expected high standard of integrity at all times. It is important to abide not only by the letter but also by the spirit of this Code.

If you have any questions or concerns about the Code or any of our Policies, you should contact your manager or the legal department (2) .


The Company expects the highest possible standards of integrity and conduct in all matters. Everyone who works for the Company should be able to trust and respect those who work with them, internally and externally, and treat each other with respect.


You should read and familiarise yourselves with all the policies and guidelines issued by the Company. Many of these are referred to in this Code, and the Policies are attached or linked to it online. Others which apply to employees only can be found in more detail in the Staff Handbooks including those on equal opportunities and health and safety. Managers should ensure effective systems of internal control are established in their area of operations.


First and foremost, the Company fully complies with all applicable laws and regulations, not only in the UK but in every country where we do business. Particular care needs to be taken by employees, or agents acting on the Company's behalf, when working outside the UK.

Managers are responsible for ensuring that employees in their areas have adequate knowledge of the key laws as well as the relevant industry codes governing their spheres of operation. This Code refers to the most important, including anti-bribery legislation, the regulatory Code of Practice of the Press Complaints Commission (Appendix A) and the Advertising Code of the Advertising Standards Authority (Appendix B). If you feel you do not have the right experience or knowledge to carry out your functions effectively you should raise this with your manager.

If there is any doubt as to whether any business practice is compliant with either the law or any relevant regulation or code, it should not be continued until it has been cleared by the legal department. Therefore, no matter in what capacity you work for or with the Company, you should seek the advice of the legal department if there are any doubts about whether a business practice is compliant.


A bribe is defined as promising or giving a financial or other advantage intending to induce another person to perform improperly one of their functions in their position of trust and responsibility, or as a reward for improper performance.

It is a criminal offence to offer or pay a bribe, request or receive a bribe and to bribe a foreign official.

The Company adopts a zero tolerance approach to all bribery and corruption and expects strict adherence to all applicable bribery and corruptions laws, by way of compliance with our Anti-Bribery Policy.

If you are unsure whether something is a bribe or could be perceived as such, please consult either the legal department or your manager. If you suspect someone of bribery or corruption, whether offering or accepting a bribe, please consult either the legal department or your manager/managing editor. We have set up a facility should you prefer to email any concerns anonymously. Whether you are on the Evening Standard or the Independent side of the business you can do so by emailing:


In the course of the Company's business, you may have access to commercially sensitive data and also personal information about employees, readers, the general public, contributors, advertisers, subjects of journalistic investigations, customers or suppliers (including payment card data). It is important that all those whose personal or confidential information we deal with have total confidence that we will treat such data lawfully and correctly.

Under the Data Protection Act 1998 the Company and everyone working for or with it must ensure that any personal data about individuals it processes - that includes use, storing, transferring, handling and so on - is accurate, relevant and up to date, and used appropriately. Whenever someone obtains information which is entered into any type of database or computer, or filed manually, the data protection principles apply. There is even stronger protection for sensitive personal data: information relating to racial or ethnic origins, political or religious beliefs, trade union membership, physical and mental health, sex life and criminal offences.

The eight principles are:

Data should be

1) fairly and lawfully processed

2) processed for limited purposes only

3) adequate, relevant and not excessive in relation to the purpose of the processing

4) accurate and, where necessary, kept up to date

5) not kept longer than necessary for the specified purpose

6) processed in accordance with the data subject's rights

7) secure

8) not transferred outside the European Economic Area without adequate protection or consent (the USA is a particularly lax jurisdiction and transfer of data there requires careful consideration)

Consult your manager or the legal department if you are in any doubt about the handling of personal information, or disclosure to a third party.

Everyone should familiarise themselves with the Data Protection Policy.


Whether we are employees, workers or business partners, we have an obligation to do what is best for the Company and to avoid situations in which our personal interests could conflict with those of the Company.

For employees

While the Company is happy to support employees having outside interests, at no time must personal interests come into conflict with those of the Company. Employees must avoid involvement in outside activities that could potentially conflict with their loyalty or might adversely affect their judgement and objectivity, or time, spent on the Company's business.

For other workers, contributors and freelances

* Conflict of interest is an issue that, in particular, our retained contributors, long term regular freelances and workers need carefully to consider as well. Even freelances who may submit only one story to us also need to notify us if there is any personal or side interest which might have a bearing on that piece.

* As a non-employee, your arrangements with the Company may leave you free to accept other work or to hold other interests but you also need to think about whether these might present you with a possible conflict of interest. You should make sure that your non-Company activities, whether personal or work-related, do not threaten the Company's reputation or interests or make it more difficult for you to perform your work for or with the Company.

* If you can see any possibility of conflict of interest, you should raise it with the person who you normally deal with at the Company (referred to throughout this Code and all our Policies as your 'link person') who will, if appropriate, refer it to their manager and/ or the legal department.

It is very important to take care to prevent any situation that could be perceived by others as being a potential conflict of interest - the perception of some act or conduct being influenced by a special, side or personal interest can be as damaging to your reputation and that of the Company as the reality would be.

The Company recognises the possibility that conflicts of interest may arise unintentionally, considering the diversity of its interests and the complexities of business practice. Therefore, you should take care not to place yourself in a position where personal or family interests, actually or potentially, conflict with the interests of the Company.

You should also consult the Anti-Bribery Policy when considering any issue to do with conflict of interest.

Ask yourself the following questions when faced with a potential conflict of interest:

* Would this relationship or situation embarrass the Company if it appeared in a newspaper or was published online?

* Am I reluctant to disclose this relationship or situation to my manager?

* Could the potential relationship or situation create an incentive for me (or be perceived as such by others) to benefit myself, my friends or family or an associated business, at the expense of the Company?

If the answer to any of these questions is 'yes', the relationship or situation is likely to create a conflict of interest and you should avoid it.

Existing interests - the requirement to review and notify

At the point this Code comes into effect, we request that every employee, worker, contributor and freelance should review their outside interests in the light of its terms. You should use the categories given below as a checklist but also bear in mind that there might be other scenarios lying outside of these categories which have the potential to present a conflict of interest. The requirements on employees are stricter, of course, but if you are someone else working for or with the Company you should read this section with care, bearing in mind that significant and damaging conflicts of interest could arise for you too.

This section highlights some of the areas in which conflicts can most commonly arise, but note that this is not an exhaustive list:

Working outside the Company

Employees may not engage in any work or position (remunerated or not) outside of the Company unless permission has been given by your manager in writing in advance. This would include for example, writing a book or articles, addressing a conference, or commercial photography. Permission will not be unreasonably withheld if the proposed activity does not affect the Company's interests.


Employees may not serve as a director of a commercial organisation outside the Company unless that office is related to a purely domestic or family matter, or one that you reasonably judge to be immate rial and/or insignificant. If you are not sure whether the directorship does pose a potential conflict of interest you should get your manager's approval in writing, in advance wherever possible.

Personal relationships

The Company recognises that particular difficulties may exist whenever an employee has family or personal relationships with people employed in a business that competes with that of the Company. If a relationship exists that could compromise your integrity as an employee, or others' perception of that integrity, you should seek advice from your manager and where necessary from senior management.

The Company also recognises that, in some cases, family members or close personal friends may work closely together or within the same department. Employees should disclose to their manager any personal relationships with other employees or with contractors or consultants where that relationship could lead (or be thought to lead) to a conflict of interest. Managers should then try to manage any potential conflict of interest that arises, but it may require changes to work arrangements or even the termination of employment of either or both individuals involved.

Purchasing decisions

The Company aims to work with organisations that share our principles and values as described in this Code.

Employees and those who work for or with the Company may not purchase goods or services on the Company's behalf from a supplier where a member of their family, close associate or a company in which they have an interest, has a material interest in that supplier, unless the employee has obtained authorisation from their manager. Approval will only be given after such a declaration when manage ment are satisfied that the transaction is at arm's length and on normal commercial terms. Employees and those who work for or with the Company cannot make any transaction where to do so would give them a benefit, whether financial or otherwise. No purchasing decision should be made on the basis of customer benefit schemes, for example Air Miles. The Company reserves the right to require employ ees to decline such benefits.

It is important when working with a supplier, or negotiating terms with a potential new supplier, that employees and those who work for or with the Company take account of the following:

* Significant new commercial contracts or purchases should normally be subject to a proper tender process, after conducting the appropriate due diligence process (see Anti-Bribery Policy)

* Orders, contract and commitments to suppliers should be awarded strictly on the basis of merit (including cost efficiency) without favouritism

* Where possible, the terms of all orders, contracts and commitments should be specified and agreed in writing

* While bearing in mind the advantages to the Company of maintaining relationships with suppliers, significant long term arrangements could prevent the effective operation of fair competition and should be reviewed and where necessary market-tested by competitive tendering at appropriate intervals.

Personal investments

Employees and those who work for or with the Company must not allow any investments held by them, their family or close associates to influence them in their work. They must declare in writing to their manager or link person any financial interest they or any close relative or associate have in any business which is a customer, supplier, partner or competitor of the Company, where the investment could be thought of as significant or material given the Company's business, or that someone might reasonably think could cause you to act in a way that benefits that personal investment at the expense of the Company.

In any event, employees and those who work for or with the Company may not:

* Hold a material financial interest (greater than five percent) in outside firms that carry out business with or are competitors of the Company without prior written approval from the Managing Editor or Managing Director; or

* Carry out any transactions on behalf of the Company in which they, or a member of their family, may personally benefit, without such prior written approval

Insider dealing/insider trading

There are laws in many territories regulating transactions in corporate securities and the securities industry. Existing legislation aims to prevent individuals from dealing in securities when in posses sion of unpublished price-sensitive information, i.e. information which, if publicly available, could affect the price of those securities. If you do not obey these laws and rules it could lead to civil and criminal actions against you or the Company.

By way of example, details of any of the following might amount to inside information:

* Mergers, acquisitions and disposals

* Proposed refinancing or restructuring

* Sale or purchase of significant assets

* Plans to issue or redeem securities

* Extraordinary borrowings

* Major litigation

* Major contracts

* Financial forecasts

* Changes in senior management or significant customers

* Fraud or impending insolvency

As general guidance, employees and those who work for or with the Company must not trade in any securities of any company on the basis of information they acquire during the course of their work for the Company which has not been made public.

Political, campaigning or charitable involvement or donations

Employees and those who work for or with the Company must avoid any associations with any political, campaigning or charitable organisation, or making contributions to such entities, which could conflict with their loyalty, might adversely affect their judgement and objectivity or time spent on Company's business, or which might reasonably be construed by others as such. Should you think that such a conflict might arise, you should discuss it with your manager.

The obligation to consult over a conflict of interest

If you are in any doubt as to whether an activity or an interest - including any that were existing when this Code came into effect as well as any which arise subsequently - could be regarded as a potential conflict of interest you must disclose any such interest:

- If an employee, to your manager

- If not an employee, to your link person.

Where necessary, your manager/ link person will consult with the legal department or the Managing Director.

Failure to notify in this way may lead to the actions set out in the FAILURE TO COMPLY WITH THE CODE OF CONDUCT OR A POLICY section below.


The Company's approach to gifts and hospitality is set out in the Gifts and Hospitality Policy. The basic principle is that you should not accept or offer gifts or hospitality which could influence editorial judgement or a business decision, could induce others to perform their functions improperly, or influence public officials. This includes any actions which could create the perception in others of any of these things. However gifts and hospitality are customary in our sector and they are acceptable provided they reflect a desire to cement good relations or show appreciation, and that they fall within reasonable bounds of value and frequency.

You should consider very carefully before offering or accepting any gift or hospitality whose value is more than merely insignificant or where it is part of a significant series of gifts over a short period: these can be called 'significant'. There may be gifts or hospitality which you are uncertain about for other reasons, they appear slightly questionable to you or maybe they just seem to fail the 'smell test': these can be called 'questionable'. In both cases, of significant and of questionable gifts and hospitality, you are responsible for notifying it - in advance unless this is not reasonably possible - by email to your manager, or if you are not an employee, to your link person. The manager concerned must keep proper records of these notifications and refer up to the Managing Editor/ departmental manager any notification they are concerned about. In addition to such referrals, Managing Editors and departmental managers will monitor the managers' own records on a regular basis to ensure the Gifts and Hospitality Policy is being adhered to by everyone concerned.

Any person who has not notified significant or questionable gifts or hospitality, or managers who have not kept proper records or have not referred up any notifications they are concerned about (or any suspicious gift and hospitality activity they become aware of) may be subject to the consequences set out in the FAILURE TO COMPLY WITH THE CODE OF CONDUCT OR A POLICY section below.


The Company is committed to ensuring business we conduct or which is conducted in the Company's name is done in a lawful, ethical and fair way. The Company's responsibility extends to acts committed in its name by business partners and agents, distributors, wholesalers, joint venture partners or partners in the Company's supply chain, that is anyone who acts on behalf of the Company: our "business partners".

You are referred to the Anti-Bribery Policy and Business Relationships Policy. You must comply with them and also take steps to ensure that business partners do likewise, for example by including an obligation to that effect in contracts with partners.

Business practices can be deeply rooted in the attitudes, cultures and economic prosperity of a particular region of the world or business sector. Effective risk assessment has to be an ongoing process and all employees have a responsibility continuously to assess the risks in their areas and operations, including reviewing their business relationships and the actions of business partners.


Each person who works for or with the Company - not just in the finance areas - has a role in making sure that money is appropriately spent, our financial records are complete and accurate and that internal controls are fully complied with. This is relevant every time we expense something to the Company, sign a contract or enter into any deal on the Company's behalf.

So, whenever you enter a business transaction on the Company's behalf there should be documentation recording that agreement, approved by the legal department.

When entering into deals with any service or product supplier, ensure that you strive for the best possible deal for the Company. This will almost always mean that you solicit competing bids to make sure you are getting the best offer. Consider all factors in making any decision including, obviously, price but also service, reliability and the terms and conditions as well as whether the third party will accept and adhere to our terms and conditions and this Code.


Company resources should never be used for personal benefit. When you submit an expense for reimbursement or spend money on the Company's behalf, make sure that the cost is reasonable, directly related to the business of the Company and supported by the relevant documentation (usually receipts). Always record the business purpose of any expenditure and identify anyone you have entertained on the expenses claim form. Claims must be submitted in a timely way and also abide by the rules on expenses published from time to time. The misappropriation of the Company's assets is strictly prohibited and anyone who witnesses or becomes aware of such behaviour should report it immediately to their manager or report it under the Whistle-Blowing section below.


We are committed to conducting business ethically and lawfully and these provisions set out the channels we have put in place to help employees and anyone who works for or with us to tell us of any concerns they may have. Our approach is to encourage you to speak honestly about any actual or suspected wrongdoing. The Company wants to hear your concerns.

The legal principles

The Public Interest Disclosure Act 1998 is designed to protect employees who blow the whistle on wrongdoing which occurs in the workplace. Under the law, employees should not be victimised or dismissed for making such disclosures.

Types of issues covered

* the commission or likely commission of a criminal offence

* a failure to comply with legal and regulatory obligations

* breach of any Company policy

* miscarriages of justice

* health and safety dangers

* HR-related issues (including discrimination, harassment, aggressive behaviour, threats or substance abuse and bullying)

* damage or likely damage to the environment

* integrity issues, such as bribery and corruption, inside information, accounting and auditing malpractices, improper gifts and entertainment, conflicts of interest and improper treatment of confidential or sensitive information.

On the last point, we draw your attention to the Anti-Bribery Policy which details how you can raise any concern with the Company, including doing so anonymously. Employees must have a reasonable belief that such an 'offence' has occurred and all disclosures must be made in good faith.

The Company's procedures

As part of the Company's efforts to create an open working environment, the Company encourages all employees to report any serious concerns, first with your manager who may be able to address any issues. If you believe that is not appropriate, we would urge you to report your concern to the legal department, managing editor, human resources director or finance director. If none of these are appropriate, you should raise it with the Managing Director.

Employees should feel free to make such disclosures without fear of reprisal, so we encourage you not to report concerns anonymously. However, all disclosures will be treated in confidence.

The Company will report back to the concerned employee after an investigation has taken place. Abuse of this process by raising unfounded allegations maliciously will be dealt with under the Company's disciplinary procedure.


Computer equipment is provided for your use for Company purposes only and should not be lent or passed to any third party without the prior permission of the Group Operations Director. All employees and others working for or with the Company who have access to the Company's computers and/ or computer systems acknowledges that data kept on these computers or systems may be confidential, and should take precautions to prevent any unauthorised access or disclosure of such data. Also see our Data Protection Policy.

Please see the Staff Handbooks for more detail for employees on the Company's computer usage policy.


The internet and any online service, including email, are to be used for business purposes only unless the prior permission of your manager or link person is obtained.

Employees are also directed to the Staff Handbooks for more detail on the Company's internet and email usage policy.


The Social Media and Online Activities Policy relates to the online activities of employees, workers and freelance contributors. It covers the use of Twitter, Facebook and other social media, posting, commenting and blogging - all ways in which you express yourself online other than by way of the approved material you create for the Company which it publishes online.

The fact is, if you work for or with the Company, readers and online users are likely to associate you with us. That means anything you state or comment may well be attributed to the Company in the public's mind, whether or not you flag up that you are tweeting or commenting in a personal capacity, and that is all the more likely if you are doing so during normal business hours. As the law in this area has not yet been clarified, there is also a risk that the Company could face a legal claim as a result of what you have written.

We have all read about civil servants or corporate staff who tweet, Facebook or comment unwisely, in what they naively believe to be only a personal capacity only, but the damage is felt by them in their work or professional standing and by their employer or entity they are associated with. This highlights the main principle: what you post or tweet is a public statement, it is hardly ever just private, and it is permanent. You need to think, always, am I happy to make this public? Use your judgement and if in doubt don't press send or enter. Apart from the well-known risk of ending up looking irresponsible in the eyes of a future employer, your job or any freelance arrangements with the Company could be put at risk: see the FAILURE TO COMPLY WITH THE CODE OF CONDUCT OR A POLICY section below.


Failure to comply with any part of the Code of Conduct or a Policy by an employee could lead to disciplinary action in accordance with the Company's disciplinary procedures, up to and including termination of employment. In the case of someone who is not an employee, the relationship or any arrangements with the Company could be terminated without notice, or such other action taken as the Company might decide.



This part of the Code concerns the way in which we carry out our journalism, the requirements we must meet with regard to publishing editorial material, and the way we respond to complaints.  It is important to remember that adherence to the  Editors’ Code of Practice overseen by the Press Complaints Commission (referred to here as the 'PCC Code'  and available at ) is a requirement of the Group’s Code of Conduct.  You should keep updated on all developments of the PCC Code and its application. Of course, adherence to the law must underpin everything we do, and there are huge implications for the Group and the individuals concerned if our obligations in that regard are not met. If anything in a story, or the means of obtaining a story, causes you any concern from a legal perspective, you should consult with Legal as quickly as possible.

Compliance with the law and regulatory good practice concerning journalism (including the PCC Code and the editorial provisions of this Code of Conduct) is expected of everyone who is involved in the material we publish – whether staff, contracted or a freelance journalist. It is a condition of our employment contracts and our continuing relationships with all those who supply or process editorial material for the Group.

The public interest

Breaking rules can sometimes be justified where there is a legitimate 'public interest' in publishing a story.  This can include such things as detecting or exposing crime or serious impropriety, protecting public health and safety and preventing the public from being misled by an action or a statement of an individual or organisation.  The public interest is not, of course, the same thing as ‘being interesting to the public’.  You should read the section on what could be in the public interest in the PCC Code.

However, breaking the law is another matter. It is no defence to certain criminal offences (e.g. phone-hacking) that any resulting story would be in the public interest.  In other criminal matters, the public interest might be a factor but you should speak to the Legal immediately if you are contemplating breaking rules.

As a general principle, if you believe that a story requires a public interest justification you should discuss the terms of that justification as precisely as possible with your desk editor and, if necessary, with other senior editorial executives or the managing editor’s office, and Legal.   Brief notes of discussions which lead to a decision to publish ‘in the public interest’ should be made wherever possible although it will not always be feasible because of deadline and other time pressures.  If in doubt, contact the managing editor’s office or Legal.


Pre-publication checks and clearance

By the time material has been filed for publication you must be confident that you have undertaken the necessary checks to ensure both its accuracy and its compliance with the law and the requirements of this Code and other regulations.  You must undertake whatever pre-publication checks and research are requested by those editors or other senior executives. If the material, or the story generally, has any legal implications you must consult Legal and carry out further checks and implement changes as required.

Identifying yourself and dealing with the public

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.

You must not intimidate or harass individuals nor engage in persistent pursuit.  If you are asked to stop questioning, contacting or photographing someone you must do so.  Public interest exemptions can apply in this area but they are likely to be rare. You should consult with managing editor’s office and Legal if there is any complaint about your conduct.

The same rules apply when contacting somebody via email, Facebook or Twitter that apply in relation to face-to-face meetings and phone conversations. 

Remember that in cases involving grief, you must conduct your enquiries with sympathy and discretion.  If you plan to approach somebody who is in hospital (or any medical institution, including a care home) you may require consent from the hospital’s authorities before doing so.


If an investigative story or any allegation of wrongdoing depends on the word of a single source you should try and get it corroborated by at least one other, unconnected and trustworthy source. In some circumstances you will need to formalise the evidence that you have obtained from a key source (eg by preparing a witness statement), and Legal will advise on this.

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.

Researching online

You should be cautious how you use the internet or social media to provide material for a story, both in terms of trustworthiness of the information or identification, and also the rights in that material.

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.

Dealings with children

There is no blanket prohibition on journalists talking to children or on using what they say for publication.  However, you must not – unless there is an exceptional public interest – speak to a child under 16 on any subject that touches on his/her, or another child’s, welfare (that is, any personal issue) without the consent of whoever has legal custody of the child.  It is not adequate to rely on consent from a teacher, a non-custodial parent or other family member, e.g. grandparent.

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 requirement or any other matter, do talk to the managing editor’s office or Legal.

Putting the story to the subject

It is not only good, responsible journalistic practice 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. This ensures that the subject is given the opportunity to point out any errors in a story as well as to comment on it so that their response can be included in the article in the interests of fairness. The more serious the allegation, the more important it is to provide the subject with a proper opportunity to respond.  You should consider whether it would be appropriate to email a request in which you set out each allegation and give the subject a reasonable amount of time to respond.  It may be advisable to consult with Legal on these matters.

Note-taking and Record-keeping

You should where possible make detailed notes and contemporaneous records of pre-publication conversations or exchanges, and these should be retained for a reasonable period (normally at least 6 months), bearing in mind that you may have to produce them as evidence in court.

It is acceptable to record key telephone conversations with people to whom you have identified yourself as a journalist provided you only use the recording as a background aid in place of handwritten notes.  If you intend to publish the recording you must make that clear at the outset and obtain clear consent.  (Note: subterfuge is dealt with below.)

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.

Use of freelances and due diligence procedures

When commissioning material from a freelance individual or entity, for example an outside investigative company, you should ensure that they are professional, reliable and trustworthy, and that their record on standards of work and conduct makes them suitable for an association with the Group. If you are in any doubt, refer the issue to your desk head and the managing editor’s office for assessment. 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.

Payments for information/sources

It is the Group’s rule that we do not pay individuals or agencies for information about third parties that could breach their rights. However, there are exceptional circumstances when it could theoretically be acceptable: where the story would be in the public interest. If you are considering making a payment in money, expenses or money's worth to any person for information or as a source you must fill in an Approval Form  (available on the Group’s intranet and here as Appendix C), and submit it for the approval of the managing editor’s office and to Legal.

Please note the relevant terms of the PCC Code in relation to payment to witnesses or criminals. Crucially, you must be aware that any payment to a police officer or public official will breach the law and can provide no legal justification.

Subterfuge and the use of improper or illegal journalistic methods

No one should break the criminal law in their work for the Group. That of course includes phone or computer hacking, blagging and trespass. 

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 (available on the Group’s intranet or here as Appendix D).  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 sent to the desk head, managing editor’s office and Legal, generally before you embark on any sort of undercover investigation, no matter how apparently insubstantial. Failure to get advance approval could lead to regulatory non-compliance 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, it is crucial you refer it urgently to managing editor’s office and Legal so that the situation can be properly assessed.


Conflicts of Interest

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. You should declare an interest before publication to the desk head or managing editor’s office when you are involved with something with which you have a significant connection. The desk head should then decide whether a declaration should appear in any relevant article. See the Conflicts of Interest Policy.

Financial Reporting

Even where the law may allow, our journalists - whatever their status: employed, contracted or freelance - should never use for their own profit financial information they receive in the course of their work before such information is published, nor should they pass such information to others. You must inform your desk head of any significant interest in any shares or securities that you know you or your close family/ associates hold before writing about such shares or securities. You must not buy or sell, directly or through nominees or agents, shares or securities about which you have written recently or intend to write.

If anyone writing about financial information is concerned about a potential conflict of interest, they must raise their concerns immediately with their desk head. There are special rules for those working on the business and city desks whereby they must ensure that an accurate and updated record is kept by their desk head or managing editor’s office of all relevant investments and interests.

Confidentiality and other agreements

If you are presented with a confidentiality agreement, a book or speech embargo for example, you must pass it to your desk head and Legal. Signature of such an agreement might bind not only your desk, but your title and company. You should not sign it or take on such a commitment without consulting whether that is in the Group's interests.

If you agree with a content provider that our use of a story, picture or video material should be restricted, either in terms of our initial publication or our syndication or exploitation of it, then you should inform Legal who will issue the appropriate restricted rights warning.



It is our primary endeavour to publish information that is accurate and will not mislead readers.  You must not fabricate information or distort it either by disingenuous phrasing or by omission.


All substantial material and quotes must be attributed correctly (ie. by author and/or by title of the publication), whatever the source of such material, including another newspaper, agency, writer or journalist. To reproduce material or quotes without a full and correct attribution is, in most circumstances, plagiarism.  Sources should be identified unless their security or a prior agreement of confidentiality dictates otherwise. The principle is to give transparency to our readers and users. Images should, similarly, be appropriately captioned.

Copy/ picture approval

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 the managing editor’s office.

Quotes - direct and anonymous

If quoting someone directly, you should 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.

Reporting suicide

Evidence suggests that media reporting of suicide can influence others who are suicidal or mentally fragile to take their own lives.  When reporting suicide you should avoid excessive detail about the method used: information that amounts to a step-by-step guide will be too much.  Care should also be taken not to glamorise suicide or its victims; and not perpetually to repeat details of past suicides at a particular place.

Privacy – general provisions

We should avoid intrusions into people's privacy, that is reporting details about their personal lives unless there is a clear public interest in doing so. For example, you should take care if thinking about reporting: addresses (or identifying private homes directly or indirectly); potentially sensitive medical information; and information obtained in personal communications including email or limited access social media. The English law can be used to protects an individual’s privacy rights no matter where in the world that person is based.

In cases involving bereavement or shock, sensitivity and discretion are especially important, not only because of the personal impact on individuals but also because  the PCC Code does not permit any public interest justification for intruding into a person’s grief.  We should not report gratuitous information about a person’s death or make light of genuine tragedies.  Images of dead bodies (especially if the individual is identifiable) should be avoided except in exceptional circumstances, for instance in connection to reporting atrocities of war.

The Data Protection Act (the 'DP Act') has the potential to impact journalists in two ways: 1) you might try to obtain information from people or organisations who will cite the DP Act as a reason for refusing to divulge information; and/or 2) as a person who is processing data, you have to comply with the Act when writing about personal information.  More information about this is contained in the Data Protection Policy, and you should consult Legal if you have any queries.

Privacy - and pictures

Individuals must not be photographed in places where they have a ‘reasonable expectation of privacy’.  This does not only refer to private property owned by the individual in question. Churches, cafes, places of work and hotels have all been regarded by the PCC as places where there can be a reasonable expectation of privacy, and even public beaches. However, each case must be judged on its merits.

Privacy - pictures of children and vulnerable adults

Under 16s must not be photographed on subjects about their welfare – or the welfare of other children – without the consent of their custodial parent/guardian.  It is imperative that there is no room for debate about whether consent has been granted and you should always err on the side of seeking clarity before photographing, if there is any doubt.  This restriction, as well as the restriction on interviewing children referred to above, carries over into publication.  In essence, even if the information or pictures have not come directly from the child him or herself, we should consider whether their use without permission might infringe their privacy.

A public interest justification for breaching either this Code or the PCC Code in cases involving children must be classed as ‘ exceptional’. 

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’.   The PCC Code places limitations on access to hospitals and other institutions.  It is vital to be aware of those restrictions.

Privacy – material from social media

Social media provides a wealth of information, some of which may legitimately be used by mainstream media.  However, the internet can present an ethical vacuum and you should not assume that simply because something appears online it can be published by us.  You  must make a careful assessment of the veracity of information you find online – and of its apparent origins.  For instance,  can you be sure who uploaded the information:  how do you prove that the person who apparently tweeted, commented or uploaded a photograph actually did so themselves?

It is also vital to consider whether republication in a major news outlet might invade someone’s privacy.  Some of the things to consider in this regard are:

• What is the nature of the material (is it intrinsically private)?

• Who uploaded it and why?  Did they intend that it be widely published?

• How widely has it been/can it be seen?

• Has that person waived their right to privacy in whole or as regards this particular aspect?

Is there the public interest to justify a possible invasion of privacy? Remember that a person’s right to privacy is not automatically lost, simply because material about them has circulated online to some degree.

Your use of social media

As a journalist employed by or associated with the Group, material which you publish– for example, tweets, blogs, comments and images – helps our titles and websites gain exposure, audience and profile. Less welcome, this material could also confer legal liability on the Group, or the Group might suffer reputational damage as a consequence of what you publish, even if you intend it only to be in a personal capacity.  Despite the apparent informality and carefree feel of such online activities, they are publications in law and carry all the same implications. As the Social Media and Online Activities Policy makes clear, you need to give the careful consideration as you would to material you are creating for print publication, not only in your own interest but also that of the Group. Talk to Legal or managing editor’s office before sending a tweet or comment if you have any legal or regulatory concerns.

Responsibility of editorial staff and contributors

It is the responsibility of every desk head, but also everyone working in or for Editorial, 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 Legal as appropriate.


Complaints Handling

If you receive any kind of complaint about a story you have been involved with, you should forward it to the managing editor’s office and Legal as soon as possible. You should not make any response on your own initiative, however insignificant it might seem. If you indicate that a remedial course of action might be possible  - which could include an apology or correction, promising a change to the online article, or running a letter – this could be construed as an admission of liability on behalf of the Group. Hence, you should not do so without the express approval of the managing editor’s office or Legal. You should co-operate fully with any investigations undertaken by the managing editor’s office or Legal in response to such complaints, and make full disclosure of all information, including documentary evidence, in your possession or of which you are aware.


If we publish information that turns out to be inaccurate it is important that the position be corrected, even if no complaint is received.  Sometimes an online amendment may be suitable, at other times it may be appropriate to publish a correction or an apology in print.  Decisions about remedial action should be made in conjunction with the managing editor’s office and Legal.


Failure to comply with any part of the Code of Conduct or a Policy by an employee could lead to disciplinary action in accordance with the Group's disciplinary procedures, up to and including termination of employment. In the case of someone who is not an employee, the relationship or any arrangements with the Group could be terminated without notice, or such other action taken as the Group might decide.

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