This code is designed to supplement ProPublica’s Conflict of Interest Policy (required by the Internal Revenue Service) and set out our expectations and aspirations for the conduct of our newsroom and editorial contributors. Employees who are not involved in the shaping of ProPublica’s editorial content are also expected to adhere to the highest of ethical standards, with certain separate guidelines as outlined below.

The mission of ProPublica is to practice and promote investigative journalism in the public interest. All of the values stated here, and the rules set out here, are intended to contribute to that mission. Much of the language below draws on similar policies in place at other distinguished American news organizations. The code also reflects what we and others have learned over many years. At the same time, however, this code is not immutable. Most of it consists of guidelines; exceptional circumstances may require exceptions to these rules. We expect to continue to learn, and, as we do so, to revise this document in light of further insight and experience.

Everyone affiliated with ProPublica is encouraged to discuss the matters within the ambit of this code and to make that discussion a continuing part of our work. Indeed, the most important wisdom about dealing with these questions is: When in doubt, ask.

It is an essential prerequisite for success in the news business that we tell the truth, and that our readers believe us to be telling them the truth. If we are not telling them the truth — or even if they, for any valid reason, believe that we are not — then ProPublica cannot succeed. ProPublica will suffer, for example, if our readers cannot assume that:

• Our facts are accurate and fairly presented.
• Our analyses represent our best independent judgments rather than our preferences or those of our sources.
• There are no hidden agendas in any of our journalistic undertakings.

All organizations profess integrity. But the impact of our work on the work of others, and on their lives and fortunes, places special responsibilities upon all ProPublica employees.

How We Do Our Work

These responsibilities include following several important guidelines in our approach in newsgathering, while writing and editing, and after publication.

We strive to identify all the sources of our information, shielding them with anonymity only when they insist upon it and when they provide vital information — not opinion or speculation; when there is no other way to obtain that information; and when we know the source is knowledgeable and reliable. To the extent that we can, we identify in our stories any important bias such a source may have. If the story hinges on documents, as opposed to interviews, we describe how the documents were obtained, at least to the extent possible. We do not say that a person declined to comment when he or she is quoted anonymously.

Editorial employees should assess with supervisors the appropriateness of any unnamed sources in stories. As part of that, editors may ask to know their identity. Sources need to understand this practice. When a source chooses to provide material to ProPublica anonymously, editors and reporters should take special care to verify its authenticity.

We don’t misidentify or misrepresent ourselves to get a story. When we seek an interview, we identify ourselves as ProPublica journalists. When testing computer systems, such as algorithms and websites, we may create user profiles that conform to characteristics that are the subject of our test. We do so only when necessary and only for the purposes of the test.

We don’t pay for interviews.

We don’t plagiarize.

Nothing in our work should be fabricated. We don’t use composite characters or fictional ages, places or dates in our stories. Our default for identifying sources is by using full names; pseudonyms can only be used in extraordinary situations with the approval of the editor in chief or a managing editor.

Overall, we must be fair. Investigative reporting requires special diligence with respect to fairness. Whenever we portray someone in a negative light, we should make a real effort to obtain a response from that person. We should give them a reasonable amount of time to get back to us before we publish. What is “reasonable” may depend on the urgency and competitiveness of the story, but we should do our best to make sure people are not surprised by what we write about them. If we don’t reach the parties involved, we should explain in the story what efforts were made to do so.

Whenever we publish data we should make diligent efforts to verify and validate the integrity of the data set and explain how to correct any inaccuracies.

No story is fair if it omits facts of major importance or significance. Fairness includes completeness.

No story is fair if it misleads or deceives the reader. Fairness includes honesty — leveling with the reader.

Any time a question of fairness or accuracy is raised about any aspect of our work, whether by a source, subject or member of the public, the reporters involved should discuss the issue with their supervising editor and decide what response is warranted. When mistakes are made, they need to be corrected — fully, quickly and ungrudgingly.

Obligations Applicable to All Employees

Acceptance of a position at any level or in any part of ProPublica includes acceptance of individual responsibility to uphold ProPublica policies governing legal and ethical business practices, as well as the responsibility to stress proper ethical behavior among colleagues and subordinates.

Any and all information and other material obtained by a ProPublica employee in connection with his or her employment is strictly the property of ProPublica. Such information includes not only our own work and that of our colleagues, but also information relating to future activities, including as-yet-unpublished news, as well as schedules for publishing the same. Such material should never be disclosed to anyone outside ProPublica, including friends and relatives, other than for reporting purposes. In no event should any information obtained in connection with ProPublica employment be disclosed privately to anyone until such information has been made available to the public.

Similarly, the use of ProPublica property of this sort — i.e. forthcoming news — as a basis for any investment decision is strictly prohibited. No employee with knowledge of any such forthcoming material may, prior to publication, buy or sell securities or in any way encourage or assist any other person in buying or selling securities, directly or indirectly, based on that information.

All ProPublica employees are expected to conduct themselves at all times in a manner that leaves no grounds for belief, or even suspicion, that:

• The creation or dissemination, or non-dissemination, of any news or other information was influenced by a desire to affect the price of any security;
• An employee’s personal financial situation with respect to investments is such that it creates a temptation to violate these rules; or
• An employee is beholden to newsmakers, information providers or market participants, creating a temptation to violate these rules.

No ProPublica employee should permit their ProPublica affiliation to be noted in any outside organization’s materials or activities without the express written approval of the editor in chief, a managing editor or the president, unless the employee serves as a representative of ProPublica or the affiliation is merely noted as part of a broader description of the employee’s identity.

It is important to take care not to discuss confidential company matters with family members or business or social acquaintances or in places where one can be overheard. Within ProPublica, confidential information should be divulged only to other employees who need to know the information in order to carry out their job responsibilities.

ProPublica employees should not offer or provide to current or prospective sources, donors or prospective donors, or vendors or prospective vendors, directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place. Nor should employees offer or provide, directly or indirectly, any material, equipment or services to any individual in a position to make or influence any business, philanthropic or governmental decision affecting ProPublica.

Conversely, ProPublica employees should not solicit or accept, directly or indirectly, any payment, loan, services, equipment or any other benefit or thing of value, or any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place from suppliers or vendors, or from any company, individual or institution that furnishes or seeks to furnish news, information, material, equipment, supplies or services to ProPublica, or from anyone else with an actual or prospective business relationship with ProPublica. Thus, for instance, we accept no free trips. Beyond that, we neither seek nor accept preferential treatment that might be rendered because of the positions we hold.

ProPublica employees may not serve as directors or officers of any company devoted to profit-making, with the following exceptions:

• Companies that are owned by an employee’s family, where the employee has obtained the written consent of the editor in chief or president of ProPublica.
• Otherwise as approved in writing by the editor in chief or president of ProPublica.

Finances, Gifts and Services

In making personal investments, all employees must avoid speculation or the appearance of speculation based on the exploitation of information not available to the public. No editorial employee of ProPublica may engage in short selling of securities.

In addition, editorial personnel must not engage in the short-term trading of equity securities or of non-investment grade fixed-income securities; employees must hold such securities for a minimum of six months unless, in order to meet some special need, they get prior permission for an earlier sale from the president of ProPublica. The six-month rule does not apply to publicly available diversified mutual funds or to similarly diversified non-leveraged ETFs.

Editorial personnel also must not buy or sell futures or options. However, these employees may invest in equity index-related products and publicly available mutual funds or commodity pools that invest in futures or options.

No editorial personnel assigned to cover a specific industry may buy or sell securities in any company engaged, in whole or significant part, in that industry. Editorial personnel reporting a story that could affect the price of an individual security they own must disclose the ownership of that security to their editor or supervisor. (This also applies to buying, selling or holding mutual funds or ETFs that invest predominantly in the specific industry that editorial personnel are covering.)

Upon being hired, and from time to time during employment as determined by editorial managers (such as when starting a new assignment), editorial personnel will be asked to affirm that they have no investments or business dealings that would violate this code with respect to the assignment they are being given. Such personnel will also be asked to affirm that to the best of their knowledge no spouse, family member or partner has financial or business holdings that might reasonably raise doubts about the impartiality of the employee’s work in their assignment. If the employee is unable to make this affirmation, the employee may choose to sell the relevant holdings or will be reassigned to avoid any potential conflict. Such personnel have an active duty to raise potential concerns with their managers whenever they might be relevant.

We should disclose in the text of a story if the subject of our reporting is a donor.

Public Life

Many organizations, for a variety of reasons, participate in the partisan political process, at various levels of government. As a publisher, ProPublica is different. ProPublica does not contribute, directly or indirectly, to political campaigns or to political parties or groups seeking to raise money for political campaigns or parties, and ProPublica does not and will not reimburse any employee for any political contribution made by an employee. All editorial employees should refrain from making political contributions or participating in partisan politics — including signing petitions, attending marches or rallies, displaying lawn signs, wearing campaign paraphernalia or displaying any other form of political partisanship.

However, editorial personnel may participate in issue-oriented activities, such as expressing support for human rights or denouncing discrimination because of a person’s race, religion, ethnicity, gender or sexual orientation. For example, working at ProPublica would not preclude an employee from marching in a Pride parade; however, it would not be permissible for an employee to participate in a rally supporting or organized by a political party. Be mindful, though, that events can take on a partisan tone, and participation should not be inconsistent with this code.

Editorial personnel should avoid any actions that could make a reasonable reader doubt their ability to report fairly or with neutrality on the subjects of their coverage. This includes participating in groups or activities that advocate for a specific policy or political solution in the employee’s coverage area.

It is not the intention of ProPublica, or of this code, to dissuade employees from participating actively in or donating to civic, charitable, religious, public, social or residential organizations. Such activities are permitted, and even encouraged, to the extent that they:

• Do not detract from performance or effectiveness at work.
• Are, in the case of Board memberships, disclosed to an employee’s direct supervisor.
• Do not, by their extensiveness, cause ProPublica to subsidize or appear to subsidize the activity.
• Do not otherwise violate this code. In the event that a conflict arises or may arise between an outside organization with which an employee is affiliated and the interests of ProPublica, the employee should refrain from participating in the conflicting or potentially conflicting activity.

In an era of growing politicization and increased scrutiny of journalists — not only of their work but also their social media activity and participation in civic life — it is more important than ever to consider the repercussions of actions in the public arena. ProPublica employees are custodians of ProPublica’s reputation, and we have a duty to one another to prioritize that concern. While that means an editorial employee does not have as much freedom to take part in certain groups or activities, it is balanced by the powerful and influential platform we have to expose abuses of power and betrayals of the public trust by government, business and other institutions. To repeat the overarching guidance: When in doubt, ask.

Editorial personnel whose stories involve organizations to which they have donated money or time, either while working at ProPublica or before, should disclose that fact to their editor as soon as possible, such as when being given a particular assignment or pitching a project. If the donation of money or time was substantial enough that a reasonable reader might question the employee’s motives, then a discussion should be had about disclosing that information in a note attached to the story or reassigning the employee.

Upon being hired, and from time to time during employment as determined by editorial managers (such as when starting a new assignment), editorial personnel will be asked to affirm that they have no affiliations with, or have donated money or time to, political organizations in a manner that would violate this code with respect to the assignment they are being given. If the employee is unable to make this affirmation, the employee may be reassigned to avoid any potential conflict or appropriate disclosures may be made in any resulting story. Such personnel have an active duty to raise potential concerns with their managers whenever they might be relevant.

Business side employees should be mindful that their actions may reflect on ProPublica and should not conflict with ProPublica’s core mission. As always, when in doubt, you can discuss with a supervisor.

Following and Enforcing Our Code

ProPublica takes this code very seriously. All employees of ProPublica are responsible for compliance with all aspects of this code. All employees shall be required to read this code at the outset of their employment, at the time this code is issued or updated, and once a year thereafter, and to attest in writing that they have done so.

The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal.

ProPublica maintains an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his or her supervisor, or is not satisfied with the supervisor’s response, the employee is encouraged to speak with the human resources director or anyone in management whom they are comfortable in approaching. Supervisors and managers are required to report suspected violations of this code to the president. In serious cases, individuals should feel free to contact the president, the editor in chief or the board chair directly. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Anyone filing a complaint concerning a violation or suspected violation of this code or other ProPublica policies must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

No employee or director who in good faith reports a violation of this code will suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including dismissal.

Finally, and to repeat probably the most important point in dealing with these questions: When in doubt, ask.