Editorial Policy – Trade Finance Global (TFG)

Last Updated: January 2024

Published: December 2021

View a list of our contributors and writers here. If you would like write for TFG, apply here.

Contents:

1. Summary 
2. Professional practice 
3. Personal behaviour and conflicts of interest
4. The IPSO Editors’ Code of Conduct

1. Summary

The purpose of these editorial guidelines is to protect and foster the bond of trust between Trade Finance Global (TFG) and its readers, viewers, and listeners, and to protect the integrity of TFG’s journalism and publishing across all formats. 

As a set of guidelines, this document does not form part of any staff member’s contract of employment at TFG, nor part of any disciplinary, promotional, or recruitment procedure. 

However, by observing these guidelines, TFG employees will be protecting the independence, standing, and reputation of themselves and their colleagues. 

Freelancers, when working on behalf of TFG, are also expected to abide by these guidelines, though are not contractually obliged to.

2. Professional practice

Attribution

a) Anonymous quotations

TFG recognises that sources will often speak more honestly if they are allowed to speak anonymously.

The use of non-attributed quotes can therefore often assist the reader towards a more accurate understanding of a subject than if a journalist used only on-the-record quotes. 

However, if used lazily or indiscriminately, anonymous quotes can be dangerous, and can open the door to outright fraud.

TFG endeavours to be open, honest, and straightforward about its sources, even if we can’t name them specifically.

There may be exceptional circumstances when anonymous quotes are used, but they will be rare, and only with approval from the editor-in-chief. 

b) Anonymous contributions

Articles commissioned by TFG may be published anonymously or pseudonymously only in exceptional circumstances, for example, where the author’s safety, privacy, or livelihood may be compromised, and only with the permission of the editor-in-chief. 

In such cases, readers should be made aware that identities have been obscured or withheld. 

This provision need not apply to user-generated content published or reproduced on our print and digital platforms, or to authors with established pseudonyms commissioned or hosted by TFG in that capacity.

c) Credits

Staff must not reproduce other people’s material without attribution, other than in exceptional circumstances – for example, where the source cannot be identified – and only with approval from the editor-in-chief. 

The source of published material obtained from another organisation should be acknowledged, including quotes taken from other newspaper articles, through embedded hyperlinks or other means. 

Bylines should be carried only on material that is substantially the work of the bylined journalist. 

If an article contains a significant amount of agency copy, then the agency should be credited as such.

Bribery and facilitation payments

The Bribery Act 2010 creates a number of criminal offences with regard to bribery, which even if committed abroad can be prosecuted in the UK. 

These include: (i) bribery – i.e. offering someone in the UK or abroad a financial or other advantage to improperly perform an activity (whether public or private); (ii) being bribed; and (iii) bribing a foreign public official. 

In some circumstances, offers or acceptances of hospitality and/or facilitation payments paid to public officials abroad in order to secure or expedite the performance of a routine or necessary action will come within the Act. 

There is no public interest defence, although where an individual is left with no alternative but to make a facilitation payment in order to protect against loss of life, limb, or liberty, there may be a defence of duress. 

Staff should always discuss with the director or editor-in-chief beforehand if they are concerned that any payments might fall into these categories, and, if such payments are requested or made, they should inform the director or editor-in-chief of the circumstances as soon as they are able to afterwards.

(See also ‘Freebies’, in Personal Behaviour and Conflicts of Interest)

Commissioning/payments

TFG publishes content sourced from a range of paid and unpaid external contributors. 

Where appropriate, freelance rates, deliverables, and accreditation on publishing are agreed on a case-by-case basis between the freelancer and the editor-in-chief prior to accepting a submission. 

TFG supports good commissioning practice, including fair treatment of freelancers. 

Freelance rates, deliverables, and accreditation upon publishing may be altered after a submission is agreed should circumstances change, but only with the informed consent of both parties, namely the freelancer and editor-in-chief.

Commercial partners/sponsors

TFG is funded, in part, by commercial partners, who are part of the industry on which TFG reports.

As such, TFG aims to be as open, honest, and straightforward as possible with regard to identifying such partners and the nature of their partnership with TFG.

A full list of permanent, strategic partners of TFG can be found here, and this list is regularly updated with the coming and going of new partners.

With regard to sponsored content, TFG marks such content by including the logo of the sponsor in the featured image at the head of each article.

Copy approval

TFG’s general rule is that sources do not have a right to copy approval.

However, in certain circumstances, we may allow sources to see copy or quotes before publishing, and may allow them to alter such copy or quotes before publishing.

TFG is under no obligation to alter copy or quotes based on a source’s demands, but will do so in good faith and on a case-by-case basis, where TFG judges that the altered copy does not alter the accuracy, sense, or meaning of the story in question.   

Moreover, TFG avoids offering copy approval as a method of securing interviews or co-operation.

Copyright

TFG does not use content from non-authorised third-party sources – whether images, text, or other media – without obtaining the necessary permissions. 

There are limited legal situations where permission may not be needed, but TFG journalists must check with the editor-in-chief before using such copyrighted material without permission.

Of relevance here are Sections 29 and 30 of the Copyright, Designs and Patents Act 1988, which outlines so-called fair dealing exceptions for the use of copyrighted works without licensing under certain circumstances.

Direct quotations

TFG does not change direct quotations to alter their sense or meaning.

Endorsements

TFG should not agree to promote – through copy, photographs, or other material – the financial interests of prospective interviewees, contributors, or their sponsors as a means of securing access to them.

Promotional information about a subject or author provided in footnotes should be included only where, in the editor-in-chief’s judgment, it is of genuine interest or assistance to the reader.

Errors

It is the policy of TFG to correct significant errors as soon as possible.

TFG journalists and editors have a duty to cooperate frankly and openly with TFG readers and listeners and to report errors to them.

All complaints should be brought to the attention of the readers’ editors, and dealt with swiftly and on a case-by-case basis, if necessary.

In the case of significant, material errors, TFG commits to leaving a note on the article in question explaining what was updated. 

However, in the case of typos and cosmetic errors, TFG will endeavour to correct the published article as quickly as possible.

External assistance

TFG journalists should not engage the paid services of external non-journalistic agents or assistants without the prior knowledge and approval of the editor-in-chief.

Fairness

In terms of accuracy, bias, and objectivity, TFG will always distinguish between comment, conjecture, and fact.

When necessary – in TFG’s reportage – factual claims based will be referenced in full, using hyperlinks to first-hand sources where possible.

TFG takes a strong stance against unsubstantiated claims in news and content, and invites readers to demand to see further evidence and/or sources if they believe that TFG has published such a claim.

With regard to criticism or allegations concerning specific companies or individuals, TFG believes in the principle of a right to reply.

In other words, the more serious the criticism or allegation, the greater TFG’s obligation to allow the subject the opportunity to respond.

Grief*

People should be treated with sensitivity during periods of grief and trauma.

Language

Respect for the reader demands that we should not casually use words that are likely to offend.

Swear words – or curses – are used only when absolutely necessary to the facts of a piece, or to portray a character in an article.

There is almost never any need to use a swear word outside of a direct quote, and even when a swear word is used, it will be toned down by replacing its vowels with asterisks.

When quoting from non-English-language material, TFG understands the difficulty of translating such material into English with perfect accuracy.

However, TFG will nonetheless endeavour to ensure that any translation, whether provided in-house or by a third party, will be as close to the original source material as possible.

TFG publishes using British English spelling and style. This will be reflected by edits made by the TFG editorial staff.

Legal

Libel and contempt laws are complex and constantly evolving. 

The consequences of losing actions can be expensive and damaging, both to TFG’s finances and its reputation. 

TFG staff should therefore: a) familiarise themselves with the current state of the law and seek training if they feel unsure about aspects of it; and/or b) consult our in-house legal experts in the case of specific concerns as they relate to TFG content.

Libel/defamation judgments

The outcome of defamation or libel actions relating to TFG should be reported promptly, openly, and accurately.

Photographs

Digitally enhanced or altered images, videos, or audio clips should be clearly labelled as such.

Privacy*

In keeping with both the IPSO Editors’ Code of Practice and the Human Rights Act 1998, TFG believes in respecting the privacy of the individual. 

Though some areas of journalism may be intrinsically intrusive, TFG should avoid invading the privacy of any individual unless there is a clear public interest in doing so. 

Proportionality is essential, as is proper prior consideration where privacy issues may be involved.

Race

In general, TFG will not publish someone’s race, ethnic background, or religion unless such information is pertinent to the story. 

TFG will not report the race of criminal suspects unless their ethnic background is part of a description that seeks to identify them, or is an important part of the story.

Sources

Sources promised confidentiality must be protected at all costs. 

However, where possible, TFG’s sources of information should be identified as specifically and openly as possible.

Subterfuge*

TFG journalists should generally identify themselves as such when working on a story. 

There may be instances involving stories of exceptional public interest where this does not apply, but such cases will require the knowledge of and the approval of the editor-in-chief.

This applies to any information pursued or obtained by subterfuge, either by TFG journalists or others working on behalf of TFG.

Suicide*

TFG journalists are asked to exercise particular care in reporting suicide or issues involving suicide, bearing in mind the risk of encouraging others. 

This should be borne in mind both in presentation, including the use of pictures, and in describing the method of suicide. 

Any substances should be referred to in general rather than specific terms if possible. The feelings of relatives should also be carefully considered.  

Verification

Trust in the authenticity and reliability of our sources is essential. 

TFG should be tenacious in seeking reliable corroboration, and should state the level of substantiation we have been able to achieve (e.g. “TFG has been unable to independently verify this information”). 

TFG will not state as fact information about or from someone who we cannot authenticate (e.g. “A sailor who says he witnessed an act of piracy”, not “A sailor who witnessed an act of piracy”). 

Where relevant, TFG must be open with readers in saying what medium was used to conduct an interview. 

Satisfaction with sources is the responsibility of TFG journalists, external contributors, and the editor-in-chief, and TFG sub-editors should be confident in challenging the reliability of all information published by TFG.

3. Personal behaviour and conflicts of interest

While TFG values its reputation for independence and integrity, we also recognise that each of our staff members has a life outside of their employment with TFG. 

Under certain circumstances, therefore, the private activities of a TFG employee may come into conflict with the integrity of TFG as a company.

Guidelines designed to prevent such conflicts of interest are therefore necessary, and are outlined below.   

These guidelines are intended to apply to all active outside interests which, should they remain undeclared and become known, would cause a fair-minded reader of TFG to question the motives and integrity of a TFG staff member.

Note, however, that these are guidelines rather than one-size-fits-all rules. 

When writing or presenting in an editorial manner, for example, in which personal opinions may be on display, a TFG employee would be expected to have more latitude than when writing a news article, where total objectivity would be expected.

If in doubt, TFG journalists should consult the editor-in-chief regarding statements of opinion that could be interpreted as presenting a conflict of interest.

Commercial products

No TFG journalist or freelancer primarily associated with TFG should endorse a commercial product, unless with the express permission of the editor-in-chief.

Similarly, no TFG journalist should involve themselves in the production of advertisement features or advertorials.

Confidentiality

TFG’s managing directors and editor-in-chief, who have access to personal information regarding other members of staff, are required to treat such information as confidential, and should not disclose it to anyone, except in the course of discharging formal responsibilities.

Conflicts of interest

TFG journalists should be sensitive to the possibility that activities outside of work (including holding office or being otherwise actively involved in organisations, companies, or political parties) could be perceived as having a bearing on – or as coming into conflict with – the integrity of TFG’s journalism.

TFG staff members should therefore be transparent about any outside personal, philosophical, or financial interests that might conflict with their professional performance, or could be perceived as such.

Declarations of interest

1. It is always necessary to declare an interest when a TFG journalist or a freelancer working on behalf of TFG is writing or speaking about something with which he or she has a significant connection.
   
   The declaration should be made to TFG’s editor-in-chief at the earliest available opportunity, and may mean that, in the interests of full disclosure, the declaration should appear in print, on the website, or in audio form.
2.  A connection does not have to be a formal one before it is necessary to declare it.Acting in an advisory capacity in the preparation of a report for another organisation, for example, would also      require a declaration every time a TFG journalist wrote an article referring to the report.
3. Some connections are obvious and represent the reason why the writer has been asked to contribute to TFG.
   
   These should always be stated either at the beginning or at the end of the writer’s contribution, even if he or she contributes regularly, so long as the writer is writing about his or her area of interest.
4. Generally speaking, a journalist should not write about or quote a relative or partner in a story, even if the relative or partner is an expert in the field in question.
   
   If, for any reason, an exception is made to this rule, the connection should be made clear.
5. Commissioning editors should ensure that freelancers working on behalf of TFG are aware of these rules, and should be receptive to any declaration, if necessary.

Declarations of corporate interest

TFG is not part of a wider group of media companies. TFG Publishing Ltd is a standalone company wholly owned by its founders, and it does not hold any shares or investments in other companies on its own company books.

TFG therefore has no declarations of corporate interest to make at the time of writing. 

Financial reporting

While it is acceptable for TFG employees to own shares, they should not trade in the shares of companies directly covered by TFG, using information that is not yet in the public domain. 

Of relevance here is Clause 13 of the IPSO Editors’ Code of Practice:

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

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

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

Freelance work

As a general rule, TFG employees should avoid freelance writing for external publications linked to particular businesses or causes, if the contribution could be interpreted as an endorsement of the business or cause in question. 

If in doubt, TFG employees should consult with the editor-in-chief before accepting such freelance assignments.

Freebies

1. TFG employees should not use their positions to obtain private benefit for themselves or others.
2. TFG will not allow any payment, gift, or other advantage to undermine the accuracy, transparency, or independence of its journalism.
   
   Any attempts to induce favourable editorial treatment through the offer of gifts or favours should be reported to the editor-in-chief.
   
   Where relevant, payments, gifts, or other advantages should be disclosed.
3. TFG should make it clear when an airline, hotel, or other interest has borne the cost of transporting or accommodating a TFG employee.
   
   Acceptance of any such offer is conditional on TFG being free to assign and report or not report any resulting story as it sees fit.
4. It should never need to be the case that a TFG journalist’s partner, family, or friends are included in any free arrangement.
   
   When a partner, family member, or friend accompanies a TFG journalist on a trip, the additional costs should generally be paid for by the journalist or by the person accompanying the journalist.
5. TFG staff should not be influenced by commercial considerations – including the interests of advertisers – during the gathering of news and content prior to publishing.
6. Gifts other than those of an insignificant value (less than £50) should be politely returned, or may be entered for an annual raffle of such items for charity.

TFG connections

TFG staff members should not use their positions to seek any benefit or advantage in personal business, financial, or commercial transactions not afforded to the public generally. 

Staff should not, for example, cite a connection with TFG to resolve consumer grievances, get quicker service, or to seek special deals or discounts.

Interaction with readers

TFG’s most important relationship is the one with its readers, viewers, and listeners.

Courtesy applies whether an exchange takes place between TFG and its readers, whether in person or by telephone, letter, email, or social media.

Outside engagements or duties

TFG accepts the right of its employees to a private life, and the right to take part in civic society.

However, TFG staff should inform the editor-in-chief if, in their capacity as an employee, they intend to:

• Give evidence to any court
• Chair public forums or seminars arranged by professional conference organisers or commercial organisations 
• Undertake any outside employment likely to conflict with their professional duties at TFG
• Chair public or political forums or appear on platforms
• Make representations or give evidence to any official body in connection with material that has been published by TFG 

TFG journalists invited to chair debates or appear on panels as a representative of TFG should not usually accept or request payment for doing so, unless preparation or attendance at the event involves a significant investment of the employee’s private time. 

Acceptance of payment should be approved in advance by the editor-in-chief, having particular regard for other clauses within these guidelines, such as conflict of interest, declarations of interest, and endorsement of commercial products.

Travel and other reasonable expenses may be accepted. In general, TFG journalists should not provide public relations advice, especially to an audience that has paid to attend.

TFG employees should consult the editor-in-chief or a managing director if in doubt.

Relationships

TFG employees should not write about, photograph, or make news judgments about any individual related by blood or marriage, or with whom the employee has a close personal, financial, or romantic relationship. 

A TFG employee who is placed in a circumstance in which the potential for this kind of conflict exists should advise the editor-in-chief or a managing director.

4. Independent Press Standards Organisation (IPSO) Editors’ Code of Practice

TFG considers the IPSO Editors’ Code of Practice to be a sound statement of ethical behaviour for all of its journalists, marketing, and editorial staff.

The Code of Practice is published in full below so that all readers and TFG staff can familiarise themselves with it and understand its principles, applications, and implications.

Editors’ Code of Practice

The Editors’ Code of Practice sets out the rules that newspapers and magazines regulated by IPSO have agreed to follow. 

The Code is written and administered by the Editors’ Code Committee and enforced by IPSO.

The latest version of the Editors’ Code of Practice came into effect on 1 January 2021. A PDF of the 2021 Code can be found here. 

The Code

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

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

It is the responsibility of editors and publishers to apply the Code to editorial material in both printed and online versions of their publications. They should take care to ensure it is observed rigorously by all editorial staff and external contributors, including non-journalists.

Editors must maintain in-house procedures to resolve complaints swiftly and, where required to do so, co- operate with IPSO. A publication subject to an adverse adjudication must publish it in full and with due prominence, as required by IPSO.

Clause 1 (Accuracy)

i) The Press must take care not to publish inaccurate, misleading or distorted information or images, including headlines not supported by the text.

ii) A significant inaccuracy, misleading statement or distortion must be corrected, promptly and with due prominence, and — where appropriate — an apology published. In cases involving IPSO, due prominence should be as required by the regulator. 

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

iv) The Press, while free to editorialise and campaign, must distinguish clearly between comment, conjecture and fact.

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

Clause 2 (Privacy)*

i) Everyone is entitled to respect for their private and family life, home, physical and mental health, and correspondence, including digital communications.

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

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

Clause 3 (Harassment)*

i) Journalists must not engage in intimidation, harassment or persistent pursuit.

ii) They must not persist in questioning, telephoning, pursuing or photographing individuals once asked to desist; nor remain on property when asked to leave and must not follow them. If requested, they must identify themselves and whom they represent.

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

Clause 4 (Intrusion into grief or shock)

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

Clause 5 (Reporting suicide)*

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

Clause 6 (Children)*

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

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

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

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

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

Clause 7 (Children in sex cases)*

The press must not, even if legally free to do so, identify children under 16 who are victims or witnesses in cases involving sex offences.

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

i) The child must not be identified.

ii) The adult may be identified.

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

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

Clause 8 (Hospitals)*

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

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

Clause 9 (Reporting of Crime)*

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

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

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

Clause 10 (Clandestine devices and subterfuge)*

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

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

Clause 11 (Victims of sexual assault)

The press must not identify or publish material likely to lead to the identification of a victim of sexual assault unless there is adequate justification and they are legally free to do so. Journalists are entitled to make enquiries but must take care and exercise discretion to avoid the unjustified disclosure of the identity of a victim of sexual assault.

Clause 12 (Discrimination)

i) The press must avoid prejudicial or pejorative reference to an individual’s, race, colour, religion, sex, gender identity, sexual orientation or to any physical or mental illness or disability.

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

Clause 13 (Financial journalism)

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

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

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

Clause 14 (Confidential sources)

Journalists have a moral obligation to protect confidential sources of information.

Clause 15 (Witness payments to criminal trials)

i) No payment or offer of payment to a witness – or any person who may reasonably be expected to be called as a witness – should be made in any case once proceedings are active as defined by the Contempt of Court Act 1981. This prohibition lasts until the suspect has been freed unconditionally by police without charge or bail or the proceedings are otherwise discontinued; or has entered a guilty plea to the court; or, in the event of a not guilty plea, the court has announced its verdict.

*ii) Where proceedings are not yet active but are likely and foreseeable, editors must not make or offer payment to any person who may reasonably be expected to be called as a witness, unless the information concerned ought demonstrably to be published in the public interest and there is an over-riding need to   make or promise payment for this to be done; and all reasonable steps have been taken to ensure  no financial dealings influence the evidence those witnesses give. In no circumstances should such payment be conditional on the outcome of a trial.

*iii) Any payment or offer of payment made to a person later cited to give evidence in proceedings must be disclosed to the prosecution and defence. The witness must be advised of this requirement.

Clause 16 (Payment to criminals)*

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

ii) Editors invoking the public interest to justify payment or offers would need to demonstrate that there was good reason to believe the public interest would be served. If, despite payment, no public interest emerged, then the material should not be published.

The Public Interest (*)

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

1. The public interest includes, but is not confined to:

• Detecting or exposing crime, or the threat of crime, or serious impropriety.
• Protecting public health or safety.
• Protecting the public from being misled by an action or statement of an individual or organisation.
• Disclosing a person or organisation’s failure or likely failure to comply with any obligation to which they are subject.
• Disclosing a miscarriage of justice.
• Raising or contributing to a matter of public debate, including serious cases of impropriety, unethical conduct or incompetence concerning the public.
• Disclosing concealment, or likely concealment, of any of the above.

2. There is a public interest in freedom of expression itself.
3. The regulator will consider the extent to which material is already in the public domain or will become so.
4. Editors invoking the public interest will need to demonstrate that they reasonably believed publication – or journalistic activity taken with a view to publication – would both serve, and be proportionate to, the public interest and explain how they reached that decision at the time.
5. An exceptional public interest would need to be demonstrated to over-ride the normally paramount interests of children under 16.