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3 December 2009
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Guidance

Conflicts of Interest Guidelines

5 Commercial, Business and Financial Interests

It is essential that the integrity of BBC programmes or other editorial output is not undermined by the commercial, business or financial interests of any programme makers, journalists, or presenters. There must never be any suggestion that commercial or financial interests have influenced BBC coverage or the subject matter of programmes or the choice of items.

The onus is on the journalist, programme maker or presenter to let the BBC know if they have any interests which could be perceived as a conflict of interest. BBC production and editorial staff are required to declare any personal interest which may affect their employment with the BBC. These interests should be declared on a Declaration of Personal Interest Form (see section 1) and further advice is given in the staff handbook "Conflicts of Interest".

Declarations should include

  • any directorships or any consultancy work for outside organisations
  • any significant shareholdings, loans (other than private mortgages) or financial interests which they, their partners or dependant relatives have and which may in any way constitute a conflict of interest or affect the impartiality or perceived impartiality of their work
  • any holding whatsoever of shares, debentures or securities held for investment purposes when the holding exceeds 5% of the company
  • any shareholding, securities or debentures in media related companies Very senior BBC people (for instance those at Controller level and above) may be required to sell any financial interest in other broadcasting or related organisations.

Freelances are also asked to declare any commercial interests which may impinge on their work with the BBC. Independent producers should make a declaration at the time of commissioning.

Significant shareholdings should be declared by all programme people if they are in any way connected with the area in which they work or the subject matter which they cover. Some people working in news, current affairs and factual programming may be involved in investigations about a wide range of topics and may be required to declare any significant holding in any organisation. Managers will give specific advice about the detail and range of the declarations required for those working in their area.

The area of most sensitivity is financial journalism where additional rules apply. Anyone who is working on an edition of a current affairs programme or factual programme which is dealing with finance or business is in effect involved in financial journalism and should follow the specific guidance in section 5.3 below. On no account must early information acquired in the course of BBC programme work be used to trade ahead of the markets. It is illegal and unethical.

Heads of Department will be aware of other particular sensitivities in their areas and will ask for particular detailed information concerning some financial or commercial interests (see section 5.2 below on music production). Although efforts should be made to declare any interests well in advance, in some cases people will be asked to work on stories or programmes at relatively short notice and may find that they have some financial connection with the area to be covered. It is essential that presenters, reporters and production teams should have no significant connection with products, businesses or companies featured in the programmes they make or the stories they are covering. If they have any financial, commercial or business interest which might involve a conflict of interest or might be perceived to involve a conflict of interest they must inform their editor or Head of Department as soon as possible. If the editor or Head of Department considers that there could be a real or perceived conflict of interest, they should deploy another journalist or programme maker.

5.1 Presenters

In some cases the commercial activities or interests of presenters could lead to a conflict of interest. To avoid this, when contracts are negotiated, presenters should be asked to declare any commercial interests which may impinge on their on air-role or which are connected with the subject matter of the programme they present. Such information is kept entirely confidential by the BBC. In some cases, particularly for presenters of journalistic or factual programmes, commercial interests may be deemed incompatible with their on-air role.

5.2 Popular Music

In popular music programming, some key presenters have links with the record industry and particular care needs to be taken with regard to commercial interests. A range of safeguards are in place in BBC Radio music networks and in BBC Television and Online to ensure that those working in these areas declare all relevant outside interests, and do not allow those interests to influence their choice of music. In BBC Radio 1 tracks with which a DJ has any commercial connection are clearly highlighted in advance to the Editor of Music Policy.

5.3 Financial Journalism

There are additional constraints on financial journalists. People working in financial programmes for the BBC should register all their shareholdings and other financial interests or dealings. Clear advice on this is given in the BBC Guidelines for Financial Journalism which are available online and from the Editor, Economics and Business Centre.

These additional guidelines for financial journalists protect the integrity of the BBC's output in this area. It is also important to remember that there are particular legal constraints which affect financial journalism. As stated earlier, it is illegal to use financial information acquired in advance to trade ahead of the markets.

It is also illegal to promote financial services without proper authorisation from the relevant regulatory authorities. It is vital that no BBC financial journalist ever calls their integrity into question by appearing to promote any financial product or investment, especially if they or members of their immediate family have a financial interest in that product or investment.

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