CONFLICT OF INTEREST POLICIES
Guidelines for Newsroom Employees of the
San Francisco Chronicle
Sept. 13, 2002

The Chronicle strives to cover the news accurately, fairly and honestly. The following guidelines are intended to be a starting place for the many informal discussions about stories that take place in the newsroom each day.

We view any violation of these guidelines as a serious matter. Violation of these guidelines may lead to job reassignment to avoid a conflict or the appearance of one or to disciplinary action up to and including termination. Any disciplinary action affecting Guild-covered employees will be subject to provisions of the Guild contract.

[Section I of Chronicle policies cover ethical questions other than conflicts of interest.]

II. CONFLICT OF INTEREST

A newsroom’s most valuable asset is its reputation.

Without a reputation for accurate, fair and balanced reporting, we lose readers’ trust.
We keep that trust not only with honest journalism, but also with our on- and off-the-job behavior.

The following guidelines deal with how we behave on and off the job with regard to commercial endeavors, personal investments and personal conduct.

We recognize that staff members may wish to participate in outside activities including political and community affairs, supporting political candidates, expressing opinions and making money outside of The Chronicle.

At the same time, we recognize that unfettered exercise of these activities can impinge on The Chronicle’s reputation for fairness, balance and accuracy.
When these two legitimate interests — an employee’s and the newspaper’s — conflict, The Chronicle will make every effort to resolve the issue with common sense and consultation. Some conflicts have no easy solution, however, and we urge any staffer with a potential conflict to talk with his or her supervisor, the executive editor or his designee. Early disclosure and discussion are essential to good resolutions.

1. Commercial endeavors. The Chronicle believes its staff should be free to perform creative, community or personal work and to earn additional income in ways that are separate and distinguishable from their work at the newspaper and which do not conflict with the newspaper’s guidelines. Here are some specific guidelines:

a) Sources. Staffers should be wary of working for individuals or organizations likely to be among the paper’s news sources and whose employment of a staffer could appear to create a conflict of interest.

b) Endorsements. Staff members should avoid signing commercial endorsements or appearing in commercial advertisements. Staffers should not accept commercial discounts for private purchases that can be misrepresented as endorsements by — or gifts to — The Chronicle.

c) Freelance work. The Chronicle recognizes that its staff members may work for publications other than The Chronicle so long as the work does not detract from the employee’s primary responsibility to The Chronicle and as long as the publications are not competitive with The Chronicle, as described below. An employee should inform his or her supervisor, the executive editor or his designee of any such work prior to its completion.

The Chronicle owns the copyright for articles, columns, photographs and art work produced for The Chronicle or The Gate. Staff members cannot legally authorize another publisher to reprint such material — even if rewritten or updated —without The Chronicle’s written permission. This applies to use of staff work in books, magazines and newspapers and also to online services, television, motion pictures and the like. Staff members may not release to anyone outside the newspaper any unpublished material produced for the Chronicle.

Our general rule is that without written permission from the executive editor or his designee, staff members may not do work for any organization that competes directly for The Chronicle’s audience or its advertisers.

“Direct competition” means any news-oriented organization in Northern California that distributes in Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Sonoma, Yolo, Mendocino or Solano counties. This includes, but is not limited to, newspapers such as the New York Times, the Los Angeles Times, USA Today, the Wall Street Journal, as well as other publications such the Bay Guardian, SF Weekly and East Bay Express, and San Francisco Examiner, and local television, radio and online outlets. This would not include spot appearances by staffers interviewed as a result of their work in The Chronicle.

It is permissible, with prior approval of one’s supervisor, to freelance for:

•National magazines such as Time, Sports Illustrated, Dance, Parenting, Health, airline magazines or the Sunday New York Times Magazine.

•Daily newspapers that do not target the Bay Area, such as The Washington Post, Denver Post, Chicago Tribune or Miami Herald.

•Online services that are aimed at a national audience and do not target the Bay Area such as space.com, espn.com or cnet.com.

There are two exceptions to the ban on writing for national newspapers
that compete with The Chronicle (New York Times, Wall Street Journal,
etc.) — but only after The Chronicle has exercised the right of first refusal:

•Op-ed opinion articles;

•Travel articles or photographs.

d) Work derived directly or indirectly from Chronicle assignments. The Chronicle has a proprietary interest in writings or photographs that evolve directly from Chronicle assignments and beats. Such work may not be offered to others without prior written permission of The Chronicle. If a trip or assignment originated and paid for by The Chronicle results in information other than that directly requested by an editor, such material must be offered first to The Chronicle. If The Chronicle turns down the material after the material has been offered to the appropriate editors, a staff member, with permission, may go elsewhere, within the confines of this policy, i.e., to a noncompetitive organization.

2. Personal conduct. Chronicle staffers must exercise caution in their personal conduct lest they create the appearance, or the reality, of a conflict of interest.

a) Use of The Chronicle’s name: Staffers may use the name of
The Chronicle, the paper’s stationery, business cards or other materials only for purposes directly connected to their employment at The Chronicle. No staff member may use his or her employment at The Chronicle for personal use.

b) No freebies. No staff member may accept free or reduced-rate transportation, gifts or junkets from current or potential news sources, including government agencies, or the government or agent of another country. Free admission to entertainment or sports events may be accepted only for work assignments. (The Chronicle makes tickets available to newsroom staffers only when those tickets have been purchased by the newspaper or have been acquired via an appropriate promotional agreement.) No staffer should seek, expect, demand or accept tickets or gratuities using his or her employment at The Chronicle. Valuable equipment or appliances valued at more than $50 (e.g., cameras, kitchen appliances and tape decks) submitted as sample products must be promptly returned or donated to charity after professional evaluations are completed.

c) Travel and lodging. Work-related transportation, lodging and expenses are paid by The Chronicle. Free or reduced-rate transportation or lodging is accepted only in special circumstances (e.g., a military flight) and must have the approval of the executive editor or his designee.
d) Review copies. Review books, records, CDs, software or other materials received for review should not be sold by staffers unless sale proceeds are donated to charity.

e) Gifts. Politely refuse gifts from sources or subjects of coverage except those of insignificant value such as a calendar or key chain.

f) Nepotism. There is no restriction on relatives, spouses or domestic partners working in the news department except that no relative, spouse or domestic partner can report directly to a relative, spouse or domestic partner. This restriction applies to staffers in a dating relationship as well.

g) Independence. Any regular affiliation with a non-Chronicle publication or with another news information organization must be specifically approved by the executive editor or his designee.

h) Speaking engagements. Staff members must be sensitive to the appearance of conflict when they agree to address groups whose interests the paper covers. As a general rule, it is acceptable to speak at events or forums sponsored by educational or non-profit groups whose main focus is not lobbying or political activity. With the prior written approval of the executive editor or his designee, staffers may accept speaking fees, honoraria or reimbursement for travel expenses.

Staff op-ed columnists who regularly appear on the op-ed page of The Chronicle and editorial writers should consult with the editorial page editor about any speaking engagements outside the “educational and non-profit” guideline above and also must get prior written approval from that editor before accepting speaking fees, honoraria or reimbursement for travel expenses.

If any staff member has any question about the appropriateness of any speaking engagement, he or she should consult with the executive editor or his designee.

i) No implications of endorsement. Freelance writings, speeches or other endeavors should never imply that they carry the sponsorship or endorsement of The Chronicle.

j) Political activities. The Chronicle does not forbid employees from engaging in political activities but needs to prevent any appearance of any conflict of interest. Staff members who wish to become involved with any political cause or campaign should take care not to create the appearance of a conflict of interest. Political involvement could include campaign contributions, volunteer activities, public endorsements, displaying bumper stickers or posters, banners and the like. Be aware that the appearance of conflict can be created by the activities of a spouse or domestic partner. It would create an appearance of conflict, for example, if a political writer covering a campaign, or an editorial writer writing an endorsement editorial in a race, had a spouse or domestic partner active in the campaign, or had posters or bumpers stickers endorsing a candidate in the race. Use your best judgment. When there is a possible question, staff members should consult with the executive editor or his designee.

k) Community involvement. While The Chronicle encourages participation in community affairs, staff members should exercise care to avoid involvements that create either the appearance or reality of conflict of interest between those involvements and their journalistic duties. Any significant or potentially controversial community involvement should be brought to the attention of the executive editor or his designee.
l) Awards. We applaud recognition of staff members and the newspaper, but we exercise great care in which contests we enter and in which awards we accept. The general rule is that the award-granting body should be composed of professional journalists and have an established track record of fairness. We want to avoid any association with contests held by self-promoting organizations because of the appearance of endorsement or conflict of interest that may arise by a Chronicle staffer’s participation in such a contest.

m) Anonymity or off-duty work. Cases of conflict or ethical compromise are not alleviated by using a pseudonym or anonymity, or by confining the activity to off-duty hours. Any activity that may cause a conflict or the appearance of one while a staffer is actively employed may also create a conflict or the appearance of one while the staffer is off-duty, on a leave of absence or on vacation. Such potential conflicts should be brought to the attention of the executive editor or his designee.

3. Personal investments. Chronicle staffers must exercise care in their personal investments lest they create the appearance, or the reality, of a conflict of interest. Note also that there are a number of laws about insider trading and trading on inside information. These laws must be scrupulously observed.

a) Insider trading. To avoid real or perceived conflict of interest, employees as a general rule should not own stock or hold other financial interests in companies or securities they are likely to cover as part of their usual assignments. If a business reporter or other staff member with a financial interest in a company outside his or her regular beat is assigned a story concerning that company, he or she must disclose the matter with the assigning editor, executive editor or his designee before undertaking the assignment.

Similarly, editors assigned to handle stories concerning companies or investments in which they have a personal stake must advise their supervisors of their potential conflict.

b) Inside information. No members of The Chronicle staff may seek financial or other paid or unpaid benefits for themselves or others by disclosing or acting upon any non-public information (including the timing of an article’s publication in The Chronicle) acquired in the course of their employment at The Chronicle.

c) Stock trading. Staff members may not buy or sell any securities or otherwise make investments in anticipation of forthcoming articles in The Chronicle. In instances where staff members become aware of non-public information concerning a corporation as a result of their employment at The Chronicle, the staff members may not trade on that information until the information has been disseminated to the general public.

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