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NHPR Journalist Code of Ethics

Last updated: February 2024

Table of Contents

I. Introduction
II. Statement of Purpose
III. Who and What is Covered
IV. Statement of Principles
V. Conflicts of Interest
VI. Outside Work and Speaking Engagements
VII. Personal Gain, Gifts, Freebies, Loaned Equipment or Merchandise, etc.
VIII. Ethical Conduct in Coverage of News
IX. Impartiality, Politics, and Civic Engagement
X. Interacting with Funders
XI. Application and Enforcement
XII. Miscellaneous


I. Introduction

This code of ethics is based on a wide range of sources: the existing ethics codes of other news organizations, including NPR, the New York Times, and the Associated Press, among others; professional journalism associations like the American Press Institute and others; the experience and expertise of NHPR journalists; and other sources. In some instances, we have adopted the same language from other sources because their wording was just right. This code has been amended and updated several times over the past two decades, and we will continue to revise it as new information, guidance and standards become available and seem relevant.

We note the following overview from NPR’s Code of Ethics: “This handbook is intended not as a prescriptive list of do's and don'ts. Rather, it is a foundation upon which staff should consider these often-competing principles and exercise judgment in deciding how to best represent the core values of our organization and to serve our audiences with journalism they can trust.”

II. Statement of Purpose

Credibility.

As a news organization we are always testing and questioning the credibility of others. We have to stand that test ourselves.

The purpose of having a code of ethics and practices is to protect the credibility of NHPR news programming by ensuring high standards of honesty, integrity, impartiality and conduct of staff. We accomplish this by (a) articulating the ethical standards we observe in pursuing and presenting stories, (b) setting rules and policies that prevent conflicts of interest, (c) establishing guidelines for outside work and activities that may reflect on NHPR, and (d) establishing policies and procedures to ensure that the activities of NHPR that fall outside journalism - corporate underwriting, fundraising from foundations or individuals, marketing and promotional activities - do not jeopardize our journalistic independence or involve NHPR reporters, editors, hosts or producers in activities inappropriate to their role as journalists.

III. Who and What is Covered

This code covers all NHPR journalists, defined as employees who report, edit or produce news programming. It also covers all senior team members and all other staff members who frequently interact with the public, including outward-facing Director-level staff in development and marketing, Major Gift Officers, Corporate Relations Representatives and full-time staff outside content departments who regularly host. The code applies to all platforms for NHPR news content, including broadcast, online and podcasts/on-demand audio.

The code also applies to material provided to NHPR news by independent producers and freelance reporters, editors, photographers and other journalists. NHPR news expects its outside contributors to be free of conflicts of interest on stories they cover, to be fair and accurate, and to pursue stories in a manner consistent with the ethical journalism principles stated in this code. There will be instances where provisions of this code are not applicable to an outside contributor. (A freelancer who primarily does arts coverage, for example, may not in some situations be subject to the prohibition on making contributions to political campaigns.) Supervisors will make these judgments on a case-by-case basis and, if necessary, in consultation with the News Director. Because contributors in this category are not NHPR employees, the remedy for dealing with a conflict of interest or other violation of the principles of this code is rejection of the offered material as well as any future story proposals similarly affected by the conflict. As with NHPR news employees, outside contributors must disclose potential conflicts of interest when they accept an assignment or make a story pitch, and NHPR editors must make sufficient inquiries of those persons to satisfy themselves that the contributors have complied with this code.

IV. Statement of Principles

Our coverage must be fair, independent, accurate, complete and honest. As a news organization, we are expected to conduct ourselves in a manner that leaves no question about our independence and fairness. We must treat the people we cover and our audiences with respect.

To tell the truest story possible, it is essential that we treat those we interview and report on with scrupulous fairness, guided by a spirit of professionalism. We make every effort to gather responses from those who are the subjects of criticism, unfavorable allegations or other negative assertions in our stories. What we broadcast and put online is edited for time and clarity.

Whenever we quote, edit or otherwise interpret what people tell us, we aim to be faithful to their meaning, so our stories ring true to those we interview. In all our stories, especially matters of controversy, we strive to consider the strongest arguments we can find on all sides, seeking to deliver both nuance and clarity. Our goal is not to please those whom we report on or to produce stories that create the appearance of balance, but to seek the truth.

Independence means that we separate our personal opinions - such as religious beliefs or political ideology - from the subjects we are covering. As a news organization, we do not approach any coverage with overt or hidden agendas. It is not the role of journalists to be entirely objective or without bias - that is not possible - but to be conscious of bias, approach their work with an objective method, and demonstrate fairness.

Accuracy means that each day we make rigorous efforts at all levels of the news gathering and programming process to ensure our facts are not only right but also presented in the correct context. We make every possible effort to ensure commentaries are correct in assertions of fact.

We attempt to verify what our sources and the officials we interview tell us when the material involved is argumentative or susceptible to different interpretations. We are skeptical of all information gathered and report it only when we are reasonably satisfied with its accuracy. We guard against errors of omission that cause a story to misinform our users by failing to be complete. We make sure that our language accurately describes the facts and does not imply a fact we have not confirmed.

Honesty means we do not deceive the people or institutions we cover about our identity or intentions, and we do not deceive our audience. We do not deceive our users by presenting the work of others as our own (plagiarism); by editing interviews in ways that distort their meaning; or by manipulating audio in a way that distorts its meaning, how it was obtained or when it was obtained. The same standards apply to photographs and video used on NHPR online. Honesty means owning up publicly and quickly to mistakes we make in our journalism on any platform.

Treating the people we cover and our audience with respect means we recognize the diversity of the state and region on which we report, and the diversity of interests, attitudes and experiences of our audience. We approach subjects in an open-minded, sensitive and civil way.

V. Conflicts of Interest

Conducting ourselves in a manner that inspires confidence in us as independent and fair means avoiding actual and apparent conflicts of interest or engaging in outside activities, public comment or writing that calls into question our ability to report fairly on a subject.

A conflict of interest in its simplest dictionary definition is a conflict between the private interests and the professional responsibilities of a person in a position of trust. An operative word in this sentence is "trust." All of us are in positions of trust when it comes to both our audience and the people and institutions that we cover. To maintain that trust requires that there be no real or perceived overlap between the private interests and opinions of NHPR journalists and their professional responsibilities.

An employee covered by this code has the responsibility to disclose potential conflicts of interest. Revealing a conflict of interest after an individual has already participated in coverage where such a conflict exists or appears to exist can be extremely damaging to the reputation of NHPR. Covered employees must, at the time they are first assigned to cover or work on a matter, disclose to their immediate supervisor any business, commercial, financial or personal interests where such interests might reasonably be construed as being in actual, apparent or potential conflict with their duties. This would include situations in which a spouse, family member or partner is an active participant in a subject area that the employee covers. The supervisor will decide whether the interests create an actual conflict of interest or the appearance of a conflict. In the financial category, conflicts do not include a journalist's investment in mutual funds or pension funds that are invested by fund managers in a broad range of companies.

The covered employee's supervisor will decide whether their conflict of interest prevents them from reporting on a specific story. We recognize that it's not possible to completely wall our newsroom off from the surrounding community, nor do we want to encourage that. Open communication between journalists and their supervisors is essential to evaluating what conflicts of interest might jeopardize our work and how to manage them. In making conflict of interest decisions, supervisors should feel free to consult with their manager.

VI. Outside Work and Speaking Engagements

The primary responsibility of NHPR journalists is to gather, write, edit or produce content for NHPR and not work in direct competition with NHPR. An example of competing with NHPR would be breaking a story for another news outlet before reporting the story for NHPR.

Covered employees are encouraged to take advantage of other opportunities – so long as they do not interfere or conflict with the work that is done for NHPR. This may include writing books or articles, appearing on panels or television, giving speeches or teaching and lecturing. These opportunities provide the chance for employees to stretch, to reflect on their work and to broaden the reach of NHPR’s journalism.

But outside work can also present significant challenges. It places additional demands on an employee’s limited time, it requires working with organizations that have different goals and standards than NHPR does and it can sometimes present entanglements that conflict with NHPR’s journalistic independence.

NHPR must be selective about these opportunities and vigilant about the challenges they pose. Employees must seek permission in writing from their supervisor for all outside freelance and journalistic work, whether paid or volunteered, from written articles to media or speaking appearances.

Requests will not be unreasonably denied if the proposed work will not discredit NHPR, erode NHPR’s competitiveness and integrity, create a conflict of interest for the employee or interfere with the employee's ability to perform NHPR duties. Supervisors must respond within five business days of receiving a request. NHPR may revoke its permission if the employee’s department head decides that an appearance (or in some cases, recurring appearances) could harm either NHPR’s or the journalist's reputation.

Covered employees may not engage in public relations work, paid or unpaid. Supervisors may grant exceptions for certain volunteer, nonprofit and nonpartisan activities, such as participating in the work of an institution of worship, a club or community organization, or an industry or charitable organization, especially if the employee is a member of the organization in question and the work would not conflict with NHPR's journalism or mission.

In general, covered employees may not do outside work for the government or agencies principally funded by the government, or for private organizations that are regularly covered by NHPR. This includes work that would be done on leaves of absence. There may be instances in which such work will be approved after consultation with the employee's supervisor.

Covered employees may not ghostwrite or co-author articles or books with people NHPR covers, or write reports - such as annual reports - for government agencies, institutions or businesses that we cover or are likely to cover. NHPR may permit exceptions for activities that don't seem to pose a risk of undermining NHPR’s credibility.

Covered employees must get approval from the appropriate member of the senior team, such as the CEO, News Director, On-Demand Director or Vice President for Audience Strategy, for speaking to groups that might have a relationship to a subject that NHPR may cover. Generally, covered employees may not speak at corporate functions. Covered employees also may not speak in settings where their appearance is being used by an organization to market its services or products, unless it is marketing NHPR or its interests, and then only as permitted in Section IX.

Covered employees are permitted to engage in promotional activities for books they have written (such as a book tour), although they are expected to get approval from their supervisors on scheduling.

Covered employees may only accept honorariums from educational or nonprofit groups the employee does not cover/report on and which are not engaged in significant lobbying or political activity. Determining whether a group engages in significant lobbying or political activity is the responsibility of the employee seeking permission, and all information must be fully disclosed to their supervisor prior to getting permission to accept the speaking invitation.

Covered employees may not speak to groups where their appearance might put their impartiality in question. Such instances include situations where the employee's appearance may appear to endorse the agenda of a group or organization. For example, a partisan advocacy organization might ask you to be part of a training it holds for new or prospective members.

Covered employees must get permission from their supervisor to appear on TV or other media. It is not necessary to get permission in each instance when the employee is a regular participant on an approved show. Permission for such appearances may be revoked if NHPR determines they raise questions about the employee's impartiality. In appearing on TV or other media, NHPR employees should not express views they would not air on NHPR's platforms.

Any covered employee intending to write a non-fiction book or TV or movie script or other guiding documents for non-radio productions based in whole or substantial part on assignments they did for NHPR must notify NHPR in writing of such plans before entering into any agreement with respect to that work. NHPR will respond within 14 days as to whether it has any objections to the project.

If NHPR chooses to create new work, or work from an external entity is inspired by or derivative of NHPR work created by employees represented by SAG-AFTRA, and NHPR will receive revenue for that work, those creators are entitled to derivative revenue, in accordance with the Derivative Work Article of the NHPR – SAG-AFTRA Agreement.

VII. Personal Gain, Gifts, Freebies, Loaned Equipment or Merchandise, etc.

Covered employees may not accept compensation, including property or benefits of any kind, from people or institutions they cover. They may accept gifts of token value (hats, mugs, t-shirts, etc.). Unsolicited items of significant value will be returned with a letter thanking the sender but stating our policy on gifts. NHPR employees split the check when they can (i.e., they are not wined and dined by sources); NHPR employees pay for their own travel in accordance with NHPR's travel policy. There are certain instances - such as conferences and conventions - where food is provided as a convenience for the press as a whole, and in such instances it is acceptable to take advantage of this. It is also acceptable for a podcast host to receive an item of low value from an advertiser in order to represent it properly to our audience. In addition, covered employees may accept paid travel and meals for speaking engagements and awards ceremonies that are approved under the standards in Section V of this document. When there are questions about the propriety of received items, they will be handled by supervisors on a case-by-case basis.

Covered employees must conduct themselves at all times in a manner that leaves no grounds for belief, or even the appearance, that information they have gathered on the job has been used for personal gain, financial or otherwise.

Covered employees may not use any nonpublic information acquired at work for personal gain, or use their association with NHPR for personal gain. For example, an NHPR employee should not mention that they work for NHPR to try to get an unfair advantage or special treatment when buying a car, a house, etc. No NHPR employee may disclose information acquired by NHPR to anyone inside or outside of NHPR if the intent is to use that information for personal or institutional gain. This prohibition does not apply to accepted journalistic practices, such as sharing information as a member of a news pool.

NHPR covers the costs accrued by its employees in news gathering, except in unusual circumstances (like going into battle with the military). The News Director or Director of On-Demand must approve any exceptions. NHPR journalists may accept free event passes, copies of books, or materials for the purpose of doing reviews or stories.

NHPR employees cannot sell items like books, CDs, etc. that are received at NHPR for review. They belong to NHPR. They may be distributed to staff for their personal use (which may include donations to charities) after they are no longer needed.

Covered employees cannot keep any equipment or items of significant value provided by a company for test use for story purposes. Such items must be disclosed to the employee's supervisor and are to be disposed of in accordance with the ethical practices stated in this document, which usually means returning such items to the provider.

VIII. Ethical Conduct in Coverage of News

Plagiarism is an unforgivable offense and subject to termination. NHPR journalists do not take other peoples' work and present it as our own.

NHPR journalists must take special care in the use they make of information from wire service stories or reports by other news organizations. No material from another source should ever be included without attribution.

When using material from newspaper stories or news websites in their original reporting, NHPR journalists should double-check facts and other material gleaned from those stories. Too often, incorrect information is passed down from one news story to another because of the failure of one news organization to get it right. NHPR should never knowingly pass on errors in this way, and should correct errors as outlined below. Exceptions to this policy include news organizations NHPR partners with in journalistic collaborations, such as the Granite State News Collaborative or the New England News Collaborative. NHPR will only partner with other news organizations who we trust hold themselves to the same high journalistic standards.

NHPR journalists are generous in giving credit to other news organizations for stories that demonstrate enterprise or contain exclusive information. If their story inspires us to replicate it, we should give credit even if we use different sources and materials. If there is any doubt about whether to credit another news organization, the relevant department head should be consulted.

NHPR journalists must treat the people they cover fairly and with respect. They always keep in mind that gathering and reporting information may cause harm or discomfort, and they weigh that against the importance of the story. NHPR journalists show sensitivity when seeking or using interviews of those affected by tragedy or grief. They show special sensitivity when dealing with children and inexperienced sources or subjects, or individuals who have difficulty understanding the language in which they are being interviewed.

There are also legal considerations when dealing with minors - anyone under the age of 18. If you interview a minor, you must obtain written or recorded permission from the minor's parent or legal guardian before using the audio. In fact, you cannot identify the minor in any way (by name, description, location, etc.) without permission. Only if the minor is not individually identifiable - for example, the sound of a gaggle of children on a playground - do you not need to get permission. If there are other more routine instances in which a reporter wishes to use audio from a minor who is identified when permission has not been obtained, the reporter's supervisor should consult the station attorney to determine whether that might be permissible.

NHPR journalists think carefully about the boundaries between legitimate journalistic pursuit and an individual's right to privacy. We recognize that private people have a greater right to control information about themselves than do public officials and others who seek power, influence or attention. Only an overriding public need to know can justify intrusion into anyone's privacy.

NHPR journalists make sure actualities, quotes or paraphrases of those we interview are accurate and are used in the proper context. An actuality (i.e. piece of audio) from an interviewee or speaker should reflect accurately what that person was asked or was responding to. If we use tape or material from an earlier story, we clearly identify it as such. We tell users about the circumstances of an interview if that information is pertinent (such as the time the interview took place, the fact that an interviewee was speaking to us while on the fly, etc.). Whenever it's not clear how an interview was obtained, we should make it clear. The audience deserves more information, not less. The burden is on the NHPR journalist to ensure that our use of such material is true to the meaning the interviewee or speaker intended.

Journalism should be conducted in the open. NHPR journalists do not misrepresent themselves: NHPR journalists disclose who they are and don't pose as law enforcement officials, investigators or other such officials.

NHPR journalists do not use hidden microphones, recorders or cameras except in unusual circumstances. Occasionally information that serves an important journalistic purpose, such as in reporting on illegal, antisocial or fraudulent activities, cannot be obtained by more open means. In such circumstances, supervisor approval must be obtained before any taping or photographing takes place. NHPR journalists do not record phone calls without permission of the subject being recorded, which is illegal in some states, including New Hampshire.

An NHPR journalist must make clear to a source when an interview has begun or has ended so there is no question about what is or isn't for broadcast, or what is on the record or not.

If there is a question of legality in pursuit of a story, NHPR journalists should consult their supervisor. NHPR has lawyers available to assist NHPR journalists. If you have any question about the legality of your conduct, contact your supervisor, who will contact a lawyer.

NHPR journalists do not pay for information from sources or newsmakers, other than standard fees charged for government and court documents, translation services, and some other limited cases. They do not allow sources or interviewees to dictate how a topic will be covered, or which other voices or ideas will be included. They do not agree to submit questions in advance unless a specific instance is approved by their supervisor. If questions are submitted in advance, this will be disclosed in our coverage.

NHPR journalists do not sign non-disclosure agreements, except in the rarest of circumstances. Exceptions to this rule must be approved by the relevant department head. NHPR journalists respect embargoes on news unless the circumstances surrounding the embargo make adherence to it inappropriate, such as where the information has already surfaced elsewhere or a strong public interest requires the disclosure to place other news in the proper context.

Although NHPR journalists do agree to talk to sources on background or off-the-record when necessary, NHPR's strong preference is to have people on the record. Before any information is accepted without full attribution, reporters should make every reasonable effort to get it on the record. If that is not possible, reporters should consider seeking the information elsewhere.

When reporters quote anonymous sources, the editor or producer of that story has an obligation to satisfy him/herself that the source is credible and reliable, and there is a journalistically justifiable reason to let that person speak without attribution. This obligation also pertains to situations where individuals ask that their real names be withheld. The editor or producer has a twofold responsibility: (1) to make a judgment about whether it is editorially justified to let the person speak anonymously or under cover of a pseudonym or partial description, and (2) to satisfy themselves that this person is who the piece says they are. An editor should never be in the position of having to verify these things after a story has aired and a question is raised about it. If a pseudonym is used, the reporter must disclose this in the story and explain in the story why a pseudonym is necessary.

When NHPR journalists attribute information in a story to a "source" or "sources," it is assumed that these are the NHPR journalists' sources and that they have obtained the information firsthand. If this is not the case, and the sources are ones quoted by other news organizations, then those sources must be attributed to those other news organizations.

NHPR does not name victims of sexual assaults. There will at times be exceptions - such as certain instances when a victim goes public with their identity - and NHPR editors will judge these instances on a case-by-case basis.

NHPR journalists do not show scripts in advance or preview audio or print pieces to any person not affiliated with NHPR. In some cases, an NHPR journalist may review portions of a script or read back a quotation to assure accuracy. An NHPR journalist may also play audio or read transcripts of an interview to a third party if the purpose is to get that party's reaction to what another person has said.

Our corrections policy is to correct substantive errors of fact in a timely way. If a reporter, host, editor or producer believes NHPR got something wrong - or that there was a serious defect in a piece - they have an affirmative responsibility to get that on the table for investigation and possible correction. Many times NHPR learns these things when someone outside brings an error to its attention. That is one natural way of finding out. But if NHPR journalists have reason to believe there was a significant error, they should not wait for it to be pointed out. Corrections, clarifications or retractions must be approved by a supervising editor or producer before they air or are posted online. If there is any possibility the material in question poses a legal liability, supervisors should consult the station’s legal counsel.

Archival audio or audio that was obtained from a past story must be identified as such if it is used in a new piece. The listener should not be left to think that any archival or previously obtained audio was gathered in the context of the current piece. As an example, a story updating a controversy surrounding an individual would be misleading if it included new assertions of fact but only used past statements by that individual and failed to identify them as such.

IX. Impartiality, Politics and Civic Engagement

NHPR staff lead active private lives and hold a diverse range of religious, ethical and political beliefs. NHPR and its coverage are better for that diversity. NHPR encourages active participation in civic life and expressions of values. However, the decision to participate in community or national events, including posting on social media, can conflict with NHPR's core values when that participation calls into question the credibility, fairness or independence of NHPR's coverage or our respect for the people we cover and serve.

Covered employees may sit on community advisory boards, educational institution trustee boards, boards of religious organizations or boards of nonprofit organizations so long as NHPR does not normally cover them and they are not engaged in significant lobbying or political activity. Such activities should be disclosed to the employee's supervisor, and NHPR may revoke approval if it believes continued service will create the appearance of a conflict of interest or an actual conflict.

Covered employees may express support for democratic, civic values that are core to NHPR’s work, such as, but not limited to: the freedom and dignity of human beings, the rights of a free and independent press, the right to thrive in society without facing discrimination on the basis of race, ethnicity, gender, sexual identity, disability, or religion.

Similarly, covered employees can publicly speak about their identities or issues with personal resonance, and they can attend related events. But, as above, our employees should not do any of this in a way that advocates explicitly for or against a specific political outcome (e.g. a candidate's election or the passage of a particular legislative policy).

Covered employees may attend marches, rallies and other public events as well as sign petitions and participate in community matters as long as they are not political and/or the journalist is not responsible for covering the issue at hand, and as long as doing so does not interfere with coverage by colleagues at NHPR, our partners or affiliates.

Covered employees may not run for office, endorse candidates or otherwise engage in electoral politics in a participatory or activist manner. Since contributions to candidates are part of the public record, covered employees may not contribute to political campaigns or referendums, as doing so would call into question their impartiality. Covered employees should not sign petitions related to political causes or otherwise contribute support or money to political causes.

Covered employees may not serve on government boards or commissions.

When a spouse, family member or partner of a covered employee is involved in political activity, the employee should be sensitive to the fact that this could create real or apparent conflicts of interest. In such instances the employee should discuss with their supervisor to determine whether they should recuse themself from a certain story, area of coverage or project.

We recognize that there might be times where members of an NHPR employee's household will be involved in political activities. NHPR cannot and will not seek to limit those activities.

Covered employees should talk with their managers about this kind of involvement and work to avoid potential conflicts of interest in their coverage. Non-covered staff should consider how the public political activities of their households may reflect on NHPR.

Examples:

● If an NHPR journalist’s partner works for or donates to a political candidate or campaign, that journalist might need to recuse themselves from covering that race.

● If an employee’s housemate wants to put a political sign in the yard, the employee should explain why that conflicts with their job obligations; if the housemate insists, be prepared to explain to members of the public that you yourself are not taking a political stance.

● If a journalist’s kids want to display their support for a social cause, the journalist should consider whether that public stance would subject the journalist to an appearance of bias and be prepared to explain to members of the public why your children’s action is consistent with these guidelines.

● If the spouse of any public-facing staff member wanted to run for office or join a political campaign, the staff member should consider the optics of this and may want to discuss it further with their supervisor.

If you have any concerns or uncertainty about whether a potential activity may be improper, err on the side of consulting your manager. NHPR will aim to handle these situations the way we do any other potential conflict: with open communication and common sense.

X. Interacting with Funders

NHPR’s journalism is made possible by a diverse coalition of funding sources, including donations from members of the public, grants from foundations and government agencies, and paid sponsorships and underwriting. NHPR values all who support this work, and those who fund NHPR do so in the knowledge that NHPR’s journalism serves only the public. We believe our strength as a business is premised solely on high-quality, independent journalism in the public interest. All NHPR employees – journalists as well as sponsorship, communications and marketing, and development staff – are committed first and foremost to that service.

At NHPR, the journalists have full and final authority over all journalistic decisions, such as what topics we cover and what form our coverage takes. NHPR works across all departments towards the goal of supporting and protecting journalism. This means communicating with the development department to identify areas where NHPR hopes to expand reporting. It also means journalists may take part in promotional activities or events such as coordinated fund drives, listener support spots, donor events and meetings, and public radio audience-building initiatives.

But NHPR observes a clear boundary line: NHPR journalists interact with funders only to further editorial goals, not to serve the agendas of those who provide financial support.

The President/CEO will designate individuals who will serve as contacts with grant funders for purposes of solicitation and stewardship.

If NHPR reports on an organization or individual who funds us, we will disclose that relationship if the subject of the report is directly related to the thrust of the financial support we receive. For instance, if we receive underwriting from a university, and an NHPR report quotes a faculty member of that university as part of coverage of a broader, statewide issue, we would not need to disclose the underwriting relationship, as the subject of the report was not directly related to the university itself. However, if we produced a report on a major scandal involving the university’s leadership, we would disclose our underwriting relationship, both on air and digitally, at the end of the report. The News Director, in consultation with the Program Director, is responsible for ensuring underwriting disclosures are done appropriately, and for communicating with other newsroom editors the current list of underwriters.

XI. Application and Enforcement of this Code

Application and enforcement of this code is the responsibility in the first instance of every covered employee. This responsibility extends to both the employee and to every other covered employee with whom they work. We should feel free to guide ourselves by offering suggestions to our peers to help them comply with their obligations under this code.

Editors and producers have special responsibility for the application of this code to matters they are editing or producing. For each story that is produced, they must be satisfied that the standards of this code have been met.

NHPR staff who do not comply with the code may be subject to disciplinary action up to and including termination.

XII. Miscellaneous

We do not enter journalism contests or competitions when they are sponsored by groups that have an interest in influencing our coverage. All entries for contests or competitions must be approved by the relevant department head.

NHPR employees should not speak on behalf of NHPR, or its policies and practices, unless authorized to do so by appropriate company officials. All press inquiries about NHPR policies and practices must be directed to NHPR's Vice President responsible for marketing and public relations.

Generally, covered employees may not endorse products or provide blurbs for books, movies or performances using their NHPR identification. The News Director or Director of On-Demand Audio may make exceptions to this rule, such as when the author of a book is a colleague of the blurb-writer, or when podcast hosts and producers record approved promotional copy for podcasts. However, permission will be denied in other circumstances, such as when the author is a politician or someone NHPR regularly covers. Blurbs drawn accurately and in context from material that has been on our air or online are permissible.

NHPR journalists must not turn over any notes, audio or working materials from their stories or provide information they have observed in the course of their journalistic activities to government officials or parties involved in or considering litigation. If such materials or information are requested pursuant to governmental, administrative or other legal process, NHPR journalists should immediately consult their supervisor, the relevant department head, and NHPR’s legal counsel.

Generally speaking, material obtained by an NHPR journalist in the course of reporting remains that journalist’s raw material, and should not be shared with anyone outside of the NHPR newsroom. For instance, if a third party asks an NHPR journalist to listen to the full recording of an interview from which a single quote was broadcast or published, the journalist should decline that request. Just as we do not let outsiders look through our notes taken in the field, we do not share raw audio or other reporting material that is not part of a final broadcast or digital publication.

NHPR owns material that has been collected or produced by NHPR journalists in the course of their duties, irrespective of whether it has been distributed on our air, online or on-demand outright, and it may not be reproduced elsewhere without the express written permission of NHPR.

The provisions of this code are subject to the employment and other policies made generally applicable to all NHPR employees.

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