This Code is designed to supplement ProPublica’s Conflicts of Interest Policy (required by the Internal Revenue Service), and set out our expectations and aspirations for the conduct of our newsroom.

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 proudly on similar policies in place at distinguished American news organizations, including Dow Jones & Company, the Associated Press, the Washington Post and Time Inc. We do this because, while our entity is new, and our business model somewhat innovative, our ethics are neither. They reflect 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; and
• 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.

These responsibilities include following several important guidelines in our approach in news-gathering, 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 comment when he or she is already quoted anonymously.

Editors have an obligation to know the identity of unnamed sources in our stories, so that editors and reporters can jointly assess the appropriateness of using their information. Sources need to understand this practice.

We don’t misidentify or misrepresent ourselves to get a story. When we seek an interview, we identify ourselves as ProPublica journalists.

We don’t pay for interviews.

We don’t plagiarize.

Nothing in our work should be fabricated. We don’t use pseudonyms, composite characters or fictional names, ages, places or dates.

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, preferably in 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. If we don’t reach the parties involved, we should explain in the story what efforts were made to do so.

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.

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. It also includes acceptance of individual responsibility for following all legal requirements 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. 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.

In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of ProPublica may engage in short selling of securities.

In addition, all managers and all news personnel must not engage in short-term trading of equity securities or of non-investment grade fixed-income securities; such 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 open end and closed end mutual funds.

News personnel and members of management with any responsibility for news 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 news personnel assigned to report on a specific industry may buy or sell securities in any company engaged, in whole or significant part, in that industry, nor may any member of the immediate family of any such employee do so.

It is important to take care not to discuss confidential 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 customers or prospective customers, 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 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 customers, 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 which 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.

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 news employees and members of management with any responsibility for news should refrain from partisan political activity, including signing petitions, participating in marches or rallies, displaying lawn signs or making political contributions. Other political activities (including “issue oriented” activity) are permitted, but should not be inconsistent with this Code.

On the other hand, it is not the intention of ProPublica, or of this Code, to dissuade employees from participating actively in 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; and
• 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.

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

ProPublica takes this Code of conduct very seriously. All employees of ProPublica are responsible for compliance with all aspects of this Code. All new employees shall be required to read this Code at the outset of their employment, and to attest in writing that they have done so; all ProPublica employees shall be required, at the time this Code is first promulgated, to read it and so attest. In the case of all members of management, and all news personnel, such written attestations shall be required once each year.

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 director of finance & operations 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 executive chairman 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.