Conflicts of Interest
Off Air Activities
In this article
Those responsible for BBC editorial output and production, reporters and presenters may wish to undertake a range of off-air activities beyond their commitments for the BBC. Specific guidance is included in sections 3, 4 and 5 below on:-
- Letters to the press
- Writing for external publications or websites
- Writing books
- Public Speaking
- Chairing conferences
- Working with Charities
- Media training
Those working in news and current affairs areas are subject to particular restrictions and for that reason the guidance is divided into advice for:-
- those working in news and current affairs
- those working in other areas.
Advice on the appropriate use of social networking sites as an external activity is to be found in the Guidance Note on Social Networking, Microblogs and other Third Party Websites: Personal Use.
News and Current Affairs - Principles
News and current affairs output may at any time deal with any issue, cause, organisation or individual and there must be no doubt over the integrity and objectivity of editorial teams. For this reason, there are specific constraints on those working in news and current affairs areas. The guidance for news and current affairs in this section and the following section ('News and Current Affairs - Specific Guidance') applies to those working in BBC News and Current Affairs, BBC Global News and news and current affairs output in the Nations. It also applies to those working on Sport News. Guidance for those working on other sports output is to be found below.
BBC Staff, BBC Correspondents on non-staff contracts and freelances primarily known as BBC news and current affairs presenters or reporters
It is essential that BBC staff, BBC correspondents on non staff contracts and
freelances known to the public primarily as presenters or reporters on BBC news or current affairs programmes do not undertake any off-air activities which could undermine the BBC's reputation for impartiality. Nothing they do or say should bring the BBC into disrepute. No off-air activity, including writing for newspapers, magazines or websites, writing books, giving interviews, making speeches or chairing conferences should lead to any doubt about the objectivity or integrity of their work for the BBC. If BBC journalists, presenters or reporters publicly express personal views off-air on controversial issues, then their editorial or on-air role may be severely compromised.
BBC staff and freelances primarily known as presenters or reporters on BBC news and current affairs programmes must not
- state or reveal publicly how they vote or express support for any political party
- express a view for or against any policy which is a matter of current party political debate
- advocate any particular position on a matter of public policy, political or industrial controversy or other currently 'controversial subject'. (See BBC Editorial Guidelines Section 4 Impartiality 4.4.5 - 4.4.6)
- exhort a change in high profile public policy
Permission must be sought from the relevant Head of Department about the suitability of writing or speaking commitments. Heads of Department should ensure that the relevant BBC Press and Publicity manager is informed about these commitments and the dates of publication or appearance.
Contracts with presenters and reporters who are primarily associated with the BBC should reflect requirements for impartiality when undertaking off-air activities and the need to seek approval for such activities as outlined in this guidance note. Contracts should also make it clear that they should not undertake advertising, promotions or endorsements for third parties (see Section 9 below).
Freelance presenters whose primary identity is not the presentation of BBC news and current affairs programmes
In some cases the BBC may employ as freelance presenters people whose primary occupation or identity is not the presentation of BBC news or current affairs. For example, presenters may be academics or newspaper editors or columnists and they may have particular viewpoints on current affairs. The BBC would not place the same constraints on their off-air activities as would be placed on BBC news staff or mainstream news or current affairs presenters and reporters. But employment of such freelance presenters should not undermine the BBC's impartiality and it may be advisable in some cases to state on air what their main position or occupation is and, if relevant, that they hold a partial view on a topic. Such presenters should not be used to present news bulletins or major daily news programmes dealing with a wide range of issues.
Presenters whose primary identity is not the presentation of BBC news and current affairs should be asked to clear with the BBC any articles or letters to the press which directly relate to the programme which they present.
News and Current Affairs - Specific Guidance
This guidance applies to those working in BBC News and Current Affairs, BBC Global News, news and current affairs output in the Nations and Sport News.
It is important that no writing commitments undermine the BBC's reputation, its integrity or its independence.
References to the BBC
BBC staff, BBC correspondents on non-staff contracts and freelance presenters or reporters primarily associated with BBC news and current affairs programmes should not speak or write publicly about the BBC without specific, prior written approval from the relevant Head of Department. Heads of Department should ensure the relevant BBC Press and Publicity Manager is informed of any approval given to speak or write about the BBC or the broadcasting industry.
When undertaking outside activities, it is also important that no reference is made which might imply BBC endorsement of an outside commercial organisation.
Letters to the Press
BBC staff and presenters or reporters primarily associated with the BBC should clear with the Head of Department and the relevant BBC Press and Publicity manager any letter to the press which deals with the subject matter of the programmes they work on. They should also clear any letter which relates to the BBC or broadcasting or deals with any public policy, political or industrial controversy or any "controversial subject".
Articles for Newspapers, Magazines and Websites
BBC staff, BBC correspondents and freelances primarily known as BBC news
presenters or reporters should not normally write regular columns for non-BBC websites or external publications which are not published by or for the BBC.
It particular they should not write a regular column which deals with:
- News, current affairs, politics or current world affairs
- Economics, business or finance
- Matters of current political or public policy debate or industrial controversy at a local, national or international level
- Media issues
- Moral or ethical issues or religion.
Columns on sport often deal with issues of public controversy. For this reason, those who work on political programmes or mainstream news and current affairs programmes dealing with a range of issues should not write regular columns about Sport for non-BBC publications or websites. Those working on other programmes may in some cases write columns about Sport with the express approval of their Head of Department. Such columns must not focus on any political or business controversies associated with Sport and any reference to such matters must be strictly impartial. Heads of Department will require copy approval.
The Director BBC Sport and the relevant BBC News Head of Department will decide what may be appropriate for BBC Sport News journalists. Chief Adviser Editorial Policy should also be consulted. In Global News, the Nations and the English Regions, permission must be obtained from the relevant Heads of Department in Sport and News who will consult Chief Adviser Editorial Policy. If, in exceptional circumstances, approval is given for a regular column on sport, the BBC must approve all copy in advance.
Columns or regular articles on non-controversial issues
In some limited cases, with the prior written permission of the relevant Head of Department who will consult with Editorial Policy, staff and freelances may write regular articles or columns for a non-BBC publication or website on a specific non-controversial topic such as gardening or music. Columns should not deal with any public debate related to the subject matter and it is important that nothing which is written undermines the BBC's reputation for impartiality. Articles should not refer to issues which they are likely to cover on air. The Head of Department will require BBC copy approval for any such articles.
One-off articles related to topical or controversial issues
In some very limited cases, with the prior approval of the relevant Head of Department, a one-off article for a non-BBC publication or website may be written on:
- News, current affairs or politics
- Economics, business or finance
- Matters of current political or public policy debate
- Media issues
- Moral or ethical issues or religion
Any such one-off article must be in accordance with the BBC's values and written in the context of BBC marketing for programmes or in support of the BBC or its interests. BBC copy approval will be required from the relevant Head of Department. No regular column on such issues is acceptable for a non-BBC publication or website.
One off articles on sport
Heads of Department must be consulted on whether any one-off article on sport is acceptable and whether copy approval is required.
One off articles on other issues
A one-off article about a non-controversial issue may be acceptable but only with the specific approval of the Head of Department. It is important that nothing which is written undermines either the writer's or the BBC's reputation for impartiality. Heads of Department will decide whether copy clearance is required.
As outlined above, BBC staff, BBC correspondents on non-staff contracts and freelances primarily associated with the BBC will need to have copy cleared for all columns and any one-off articles related to topical or controversial issues. Heads of Department will decide whether copy clearance is required for one off articles on sport or non controversial issues.
Articles must be submitted for BBC approval in good time before the publication deadline and Heads of Department must ensure that the relevant press office is informed.
BBC staff and BBC Correspondents on non-staff contracts
BBC editorial staff and BBC Correspondents on non-staff contracts must have prior written approval from their Head of Department to publish a book on any topic. The book should not compromise the integrity or impartiality of the BBC and should adhere to all contractual requirements such as confidentiality. The copy of any book must be approved by the BBC before publication. Copy should be submitted in good time before publication to the Head of Department or their nominee. The relevant BBC Press and Publicity Manager should be informed of plans to promote and market the book.
Freelance presenters and reporters
Those primarily known to the public as presenters or reporters on BBC news and current affairs programmes should inform the relevant Head of Department about any book they propose to offer for publication before any contractual arrangements are made in relation to the book. Any books specifically about current BBC programmes would need prior BBC approval. The Head of Department will then be in a position to advise in good time whether the proposed book could affect their on air role. The relevant BBC Press Office should be informed about any commitments which presenters have made for writing books.
Books about current topics
In some cases, Heads of Department may agree that a presenter or reporter may write a book about a current topic provided it is not likely to compromise their on-air role or the integrity or impartiality of the BBC. If the book turns out to be controversial or one-sided, editors should consider whether to allow the presenter to cover on-air the issues which they have written about. If there is any possibility of a conflict of interest, the Head of Department should consider whether the presenter should declare that interest on air or not present items or conduct interviews on the issue.
BBC staff, BBC correspondents on non-staff contracts and freelance presenters and reporters primarily associated with the BBC should seek written permission in advance from the relevant Head of Department for the granting of any serialisation rights. Approvals for serialisations must also be agreed with the relevant Press and Publicity Manager. It is the responsibility of the author to inform the relevant Press and Publicity Manager about the press date for the serialisation.
Regular BBC news presenters should not undertake promotions, endorsements or advertisements for any company, outside organisation or political party. In exceptional circumstances, with the prior approval of the BBC, they may however undertake promotional activities for books which they have written. Any such activity must not jeopardise the presenter's reputation for objectivity and impartiality
Public Speaking and Other Public Appearances
BBC Staff and BBC Correspondents on non-staff contracts
BBC staff and BBC Correspondents on non-staff contracts should get written
permission from their Head of Department before undertaking any outside public appearances including speaking at conferences. They must not make any appearances which are promotional for a commercial concern and nothing they do or say should undermine the integrity or impartiality of the BBC. They should not allow the use of the BBC's name or brands in connection with advertising for a public appearance unless this has been expressly approved by the BBC. Care should be taken with appearances related to charities, particularly if they are campaigning organisations, and no impression should be given of BBC endorsement of one charity over another. It would not normally be appropriate for BBC staff or a BBC correspondent on a non staff contract to front a campaign for a specific charity. (See section below on Involvement with charities) It is not normally acceptable for any BBC staff member or BBC Correspondent to be included on an advertised agency list of those for hire for public speeches. Under no circumstances should they sign up with an external agency for public speaking without the written permission of the relevant Head of Department.
Freelance presenters and reporters
Those known to the public primarily as presenters or reporters on BBC news and current affairs programmes must remain impartial when speaking publicly or taking part in a question and answer session. They must not promote any political party, campaigning organisation or lobby group. Public appearances to promote an outside commercial organisation are not acceptable and it is important that no off-air activity implies BBC endorsement of an outside commercial concern. The onus is on presenters and reporters to inform the relevant Head of Department about the overall range of speaking commitments which they undertake and to inform them about any which may be controversial or may lead to problems concerning perceptions of impartiality. If, during a public appearance, a viewpoint expressed turns out to be controversial or one-sided, editors should consider whether to allow the presenter to cover the issue on-air.
BBC staff and BBC Correspondents on non-staff contracts
BBC staff and BBC correspondents on non-staff contracts must obtain the written permission of their Head of Department before agreeing to chair any conference. They should not chair conferences which are a promotional exercise for a commercial company, which support any political party or are one-sided and fail to represent an appropriate range of views on an issue of public controversy. Care should be taken in relation to charities, particularly if they are campaigning organisations, and no impression should be given of BBC endorsement of one charity over another. (See section below on Involvement with charities)
Freelance presenters and reporters
Presenters and reporters primarily associated with the BBC may chair conferences as part of their off-air work. Conferences they chair should not support any political party, be one-sided on an issue of public controversy or be promotional exercises for commercial companies. The onus is on the presenter or reporter to inform the relevant Head of Department about the overall range of work they undertake and about any particular commitment which may be controversial or may lead to problems concerning perceptions of impartiality.
BBC Global News
It should be noted that BBC World News is commercial concern and that BBC World News presenters may take part in some promotional events or chair conferences which are organised by BBC World News or in conjunction with others, or which are organised by third parties. Some of these events may involve BBC World Service or other areas of BBC Global News. Appearances at such events, which may involve promoting BBC World News and its associated activities, must be approved by BBC Global News Management who will take care to ensure that these activities do not undermine the integrity or independence of BBC Global News output.
There are considerable dangers of a conflict of interest if BBC people train individuals or organisations in how to present themselves on television, radio or online. BBC staff, BBC correspondents on non staff contracts and freelances known to the public primarily as presenters or reporters on BBC news or current affairs programmes should not undertake any media training work. Under no circumstances should they interview anyone they have previously trained.
Involvement with Charities
News and Current Affairs programmes may deal with any issue, cause or organisation including charities, trusts and philanthropic institutions. Charities, their work and the causes they promote may be covered at any time in news or current affairs and very careful consideration needs to be given to any proposals for individuals to become involved with charitable organisations. Any involvement should not give the perception that the BBC has a bias in favour of one charity over another or that the BBC or BBC journalists are taking sides on issues of public controversy.
It is important to bear in mind that BBC figures are usually asked to take on public roles connected with charities primarily because of their association with the BBC and any activity associated with the charity might be perceived as BBC endorsement. If BBC people take on a public role for a charity, the BBC may be considered to be advantaging one charity over another, and this may be seen to undermine our principles of fairness and impartiality. Apart from the BBC's own charities and charitable trusts and other specific appeals carried on BBC services, the BBC takes care not to be seen to endorse particular charities.
Given the sensitivities in this area, approval must be sought from the relevant Head of Department before undertaking any charity commitment. Advice may also be sought from Editorial Policy.
Assessing the suitability of charitable involvement
When assessing proposals for involvement with charities, managers should ensure that BBC editorial staff, BBC correspondents on non-staff contracts and freelances, known to the public primarily as presenters or reporters on BBC news or current affairs programmes, do not:-
- Endorse charities which are advocating a particular standpoint on matters of political controversy or public policy, as the BBC needs to be seen to represent all sides of an argument fairly and accurately
- Associate themselves with a charity which is closely involved in an area of activity about which they are likely to report
Except in relation to BBC appeals, such as Children in Need, or appeals carried by the BBC, they should not
- Appear in an advertisement for any charity
- Appear in charity fundraising appeals or in publicity for fundraising e.g. large scale mail-drops
- Front charity campaigns
- Be the public spokesperson for a charity
- Undertake media interviews on behalf of a charity
- Advise a charity on how to lobby or present itself in the media
BBC News and Current Affairs presenters, reporters and editorial staff may be asked to undertake public roles such as ambassadors or patrons of charities. In some cases it may be acceptable to undertake such roles, but not if they involve any of the activities listed above. Careful consideration needs to be given as to when such roles might be acceptable. In many cases, being an "ambassador" would be inappropriate as it normally involves campaigning for a charity. The role of patron indicates a high level of endorsement and may not be suitable. Chairing a charity probably involves even more involvement and is unlikely to be acceptable. Being a trustee may be less sensitive, but consideration needs to be given to the fact that trustees
are usually involved in ensuring the probity, good conduct and good management of a charity.
However, on rare occasions editorial staff, correspondents, presenters or reporters on BBC News or Current Affairs programmes, may have a closer involvement with a charity involved with the health, safety and wellbeing of journalists or some other charity connected to their role or experiences. Editorial Policy should be consulted about any such proposals and approval must be obtained from the Divisional Director.
Local involvement with charities
In some cases, with the express permission of the relevant Head of Department, it may be possible for News and Current Affairs people to be involved more closely at a local level with charities which are not concerned with lobbying on matters of public controversy. However care must be taken to ensure that such an involvement does not undermine their impartiality or the BBC's impartiality and that they are not involved with an organisation on which they are likely to report. This is particularly important for reporters, presenters and editorial staff on regional and local news programmes. News presenters should not normally front a campaign for any charity and any proposals to do so must be referred to Editorial Policy.
Activities connected to BBC charities, BBC Charitable Trusts and appeals carried by the BBC
BBC editorial staff and presenters may be closely involved with BBC charities and cross-BBC charitable initiatives such as Children in Need, the BBC Wildlife Fund, Comic Relief's Red Nose Day and Sport Relief. They may appear on-air in items in support of the appeals and at off air events. However, it is important that presenters do not undertake any activity in association with these charitable initiatives which gives the impression of campaigning on an issue of political or public controversy.
BBC Global News staff and presenters may have a close involvement with the BBC World Service Trust and get involved with support for Trust projects providing this could not be seen to undermine their editorial or on-air role.
In a case of a major emergency, BBC licence fee funded services may carry appeals by the Disasters and Emergency Committee (DEC). The BBC also runs Lifeline on BBC 1 and the Radio 4 Appeal, which carry appeals for individual charities chosen by a careful selection procedure. In all these cases, BBC News Management needs to give very careful consideration as to whether it would be appropriate for a news or current affairs presenter to front such an appeal and the advice of Chief Adviser Editorial Policy should be sought. Regular BBC news presenters would not normally present a Radio 4 or Lifeline appeal for a specific charity, but it may be acceptable for some current affairs presenters to front such an appeal if it does not undermine their impartiality or integrity.
Other Output Areas
In other output areas, the degree to which external activities are constrained will depend on the nature of both the output and the individual's role. It is important that any outside activities do not undermine the BBC's impartiality, bring the BBC into disrepute or damage the BBC brand. Heads of Department must judge what is appropriate and consult Editorial Policy in cases of difficulty. In factual output, including sport, care should be taken about any writing or speaking engagement connected to the subject matter of the programme. There is less concern about expressing views publicly on an unrelated area, for example a person working in science expressing an opinion on arts.
Those working on consumer programmes, either as presenters or producers, must have no financial or business links which could influence their attitude towards any product, service or company that might be covered in their programmes (See Section 7 below). Any non-BBC activity undertaken by presenters of consumer programmes, such as writing articles or books or chairing conferences, must not promote or appear to promote any product or service that might be featured in the programmes they present. Restrictions will be tightest for those working on consumer programmes which deal with a range of topics, such as Watchdog.
In all other areas, including entertainment, it is essential that programme makers, content producers and on-air talent do not undermine their own integrity, or the integrity of the BBC, by off-air involvement in inappropriate activities or commercial interests. Their off-air activities must not bring the BBC into disrepute or damage the BBC brand.
No off-air commitments undertaken by a regular BBC presenter should undermine their on-air role or lead the public to question their integrity.
Letters to the Press
Programme makers, editorial staff and regular presenters primarily associated with the BBC must clear with their Head of Department and the Press Office any letters to the press, if they deal with the subject matter of their programmes, relate to the BBC or broadcasting, or concern matters of public policy, political or industrial controversy, or any other 'controversial subject'.
Presenters who present specific series, or present programmes for the BBC only occasionally, should clear letters about their programmes with the Head of Department and the BBC Press Office. They should also normally clear letters relevant to the subject matter of their programmes if they are to be published around the time of transmission.
Writing for Newspapers, Magazines and Websites
Programme makers, editorial staff and presenters may seek to write articles for newspapers and non-BBC magazines and web sites. It is important that any writing commitments do not give rise to a conflict of interest or undermine the reputation of the BBC, or the BBC output on which they work.
Editorial staff working for the BBC should check with the Head of Department in advance as to whether a writing commitment is acceptable. If the article is about the BBC, the programme on which they work, subject matter clearly relevant to the editorial area in which they work, or any other subject which could give rise to concerns about conflicts of interest, the Head of Department would normally ask to approve the copy in advance.
Any proposals for editorial staff to write regular columns should be referred to the Head of Department who will decide what is appropriate in their area. However, no BBC staff journalist working on factual output should write a regular newspaper or magazine column dealing with current affairs or matters of public policy, political or industrial controversy. Nor should they write a column on any clearly 'controversial' subject' where there is a likelihood that the column could undermine the independence, reputation or integrity of the BBC or its output. Regular presenters on long term contracts should discuss the range of their journalistic commitments with the relevant Head of Department who will consider if there are any areas of activity which might lead to conflict of interest. In some cases they may be contractually obliged to consult the BBC about writing commitments. BBC copy approval would normally be required for any article about the programme they present. The Head of Department may also ask for copy approval for articles of particular sensitivity connected to the subject matter of the programme.
In some areas, such as sport, regular presenters or "pundits" may write articles or regular columns about the subject matter of their programmes. Heads of Department must judge the suitability of such work and whether there is any need to ask to see such articles before they are submitted for publication.
Presenters who present programmes for the BBC only occasionally, or for specific series, may undertake a range of writing commitments. However, the Head of Department should discuss with them any areas of activity which could give rise to a conflict of interest and ask to see articles in advance if they are about the programmes they present.
Programme makers, editorial staff and presenters may wish to write books on a range of topics, but it is essential that such activity does not bring the BBC into disrepute.
BBC editorial staff should inform the relevant Head of Department of their intention to publish a book on any topic. The Head of Department should consider the sensitivities in that area and whether the book could give rise to a conflict of interest or raise concerns about the integrity or impartiality of the BBC. If publication goes ahead, the Head of Department must judge whether the subject matter is such that the copy should be approved by the BBC before publication. The copy of any book about the BBC or a BBC programme must be cleared before publication by the relevant Head of Department.
Presenters and regular contributors to the BBC on long term contracts should inform the relevant Head of Department in advance about any proposal to write a book about the BBC or their work for the BBC or about the programme in which they appear. In some cases, contracts would require such presenters and contributors to ask for permission from the BBC to publish any such book. The Head of Department would usually ask to see the copy before the book is published.
Whatever the subject matter, presenters should not use their programmes as a vehicle for promoting books they have written. In some cases, it may be editorially justified to make some reference to the book, providing there has been clear prior approval from the editor or relevant editorial executive. But it is essential that the book is not "plugged" on-air.
Public Speaking and Chairing Conferences
No public speaking commitments or other public appearances, such as chairing conferences, should undermine the authority, objectivity or integrity of presenters or editorial staff working on BBC output. Any such commitment should not imply BBC endorsement of any product, or service. Presenters in factual areas should not chair conferences which are a promotional exercise for products or services related to the subject matter of the programmes or output on which they work. Great care should be taken in relation to any commitment which might appear to endorse a campaigning organisation. Heads of Department will be conscious of particular sensitivities in their area and should discuss any outside commitments with editorial staff and presenters in order to make a careful judgement as to whether activities are appropriate.
BBC presenters, editorial figures or programme makers may speak at conferences or other events about matters pertaining to broadcasting, journalism or general production.
However, conflicts of interest may arise and the BBC's editorial integrity and impartiality could be compromised, if editorial and production staff or presenters employed on our programmes train interviewees or organisations on how to present themselves in the media. Heads of Department need to make careful decisions as to what, if any, media training work might be considered acceptable. Editorial and production staff must obtain permission from their Head of Department before making any such commitments and we should ask freelance presenters about their work in this area to ensure there is no conflict of interest. Care should be taken to ensure that presenters do not interview people they have trained to appear on air.
Charities and Campaign Work
BBC staff and presenters may take part in programming and events to support BBC Children in Need, Comic Relief, Sport Relief and other BBC fund-raising appeals. (See Guidance on Cross-BBC Charitable Fundraising Initiatives.) Presenters may, where appropriate, present emergency appeals carried on BBC services and in some cases they may present a specific charity appeal carried by the BBC, such as the Radio 4 Appeal or Lifeline, providing the association with the particular charity does not undermine their impartiality or the impartiality of the programme they present.
However, any work undertaken for, or in support of, other charities or charitable causes should not imply BBC endorsement for one charity or cause above others. There will be particular sensitivities if the charity deals with, and/or campaigns on, matters of public policy, political or industrial controversy, or any other 'controversial subject'. Editorial staff and presenters working in factual areas must also take care that their impartiality is not compromised by associating themselves with a charity operating in the same area as the programming on which they work and there will be particular constraints on those working on consumer programmes. Any proposal for editorial staff or presenters in factual areas to be publicly associated with charities and campaigning groups must be referred to the Head of Department, who may wish to consult Editorial Policy.
Heads of Department in other areas must make careful decisions about what is appropriate and ask regular presenters to notify them if they intend to "front" or campaign for a charity or campaigning organisation.