Guidance Note
This guidance note relates to the following Editorial Guidelines:
- Section 4 Impartiality
- Section 14 Independence from External Interests
- Section 15 Conflicts of Interest
Introduction
Our audiences must be able to trust us and be confident that our editorial decisions are not influenced by outside interests, including political or commercial pressures.
Conflicts of interest can arise for anyone who works for the BBC in any capacity and/or is involved in producing, overseeing or appearing in BBC output. A potential conflict of interest arises when there is the possibility that an individual’s external activities or interests may affect, or be reasonably perceived as affecting, the BBC’s impartiality and its integrity, or risk damaging the BBC’s reputation. Individuals are responsible for completing a Declaration of Personal Interests form and BBC management must decide what action is necessary in response to declared conflicts of interest. In some circumstances, it may also be appropriate to consider whether the position of families and close personal contacts presents a likely conflict of interest.
This guidance covers people working in all areas of the BBC – however they are employed – and also applies to BBC Studios making content for any party and independent producers making content for the BBC Group. There are specific details which apply to people working in particular areas. Where there is guidance for news, this includes BBC News and Current Affairs, BBC Global News, news and current affairs output in the nations and regions and Sport News. There are also additional requirements for those in factual output and consumer affairs journalism where, although not part of news, the audience expectation for impartiality is high.
This guidance incorporates the additional restrictions around financial journalism to prevent individuals profiting from specific information they may have or passing it on to third parties and the restrictions in place around the promotion of financial services or products.
Guidance in full
- Contractual arrangements
- News, current affairs, factual and consumer journalism
- Membership and activity
- The level of political activity
- The nature of the BBC role
- The type of programme
- Elections - Seeking Nomination or Declaring Independent Candidacy
- Elections - Candidates
- Elections - Afterwards; successful and unsuccessful candidates
Non-political Voluntary Public Office
- Charities and Campaign work – additional considerations in news and current affairs, factual and consumer output
- Assessing the suitability of charitable involvement
- Local involvement
- Activities connected to BBC charities and appeals carried by the BBC
- Writing/publishing commitments – one-off articles/podcasts and regular columns
- Writing commitments – one-off articles and regular columns relating to sport
- Writing/publishing commitments – additional requirements in news and current affairs
- Writing books
- Writing books – additional requirements in news and current affairs
Public Speaking and other Public Appearances, including Chairing Conferences
- Additional requirements in news and current affairs, including sports news, and in factual and consumer output
- BBC Global News
Personal and Outside Interests
- Commercial, business and financial interests
- Specialist music
On-air talent - Commercial Advertising, Promotions and Endorsements
- Unsuitable Products or Services
- Advertising/promotional Commitments and Editorial Integrity
- Timing of Advertisements/Promotions
- News and Current Affairs (including Sports News), Consumer and Factual output and Business output
- Lifestyle programmes
- Cookery Programme Presenters
- Presenter’s Own Products
- Advertising and Marketing of Presenter’s Own Products
- Sport
- Presenters and Regular Panellists of Sports Quizzes and Sports Entertainment Programmes
- Children’s Programmes
- Entertainment/Factual Entertainment
References to BBC Content in Advertisements
- Voiceovers
- Actors and Artists who perform in BBC content
Talent- or Agent-Owned Independent Content Production Companies
- Factual Programmes
- Entertainment, Factual Entertainment and Music Programmes
- Drama and Comedy Programmes
External Activities
The external activities of people involved in making or presenting BBC content has the potential to risk damaging the BBC’s reputation, by bringing its impartiality or independence into doubt or otherwise compromising the BBC’s integrity. This risk extends to people who have regular roles in BBC output and as a result are associated with the BBC, such as regular members of talent show judging panels and quiz team captains.
In all areas it is essential that managers, content producers, commissioners and those who support them and on-air talent do not compromise their own integrity, or the integrity of the BBC, by off-air involvement in inappropriate activities or commercial interests. Their off-air activities must not bring the BBC into disrepute or damage any BBC brand.
The principles on conflicts of interest apply to everyone, but how they are applied will vary according to an individual’s role and their level of involvement with BBC content. This reflects audience expectations of the impartiality and integrity of BBC output - in particular, in news and current affairs and in factual and consumer affairs output.
Contractual arrangements
Contractual arrangements for regular presenters or presenters of a series of programmes will reference this guidance. On-air talent should be made aware of this guidance and Section 15 of the BBC Editorial Guidelines and those who work for the BBC other than on an occasional basis should be required to consult the BBC before undertaking any outside advertising/promotional work.
In rare cases some existing contracts may not require adherence to the latest Guidance, though of course they will always require adherence to the BBC Editorial Guidelines. However renewed contractual arrangements should require talent to conform to this current Guidance.
News, current affairs, factual and consumer journalism
News and current affairs output may deal with any issue, cause, organisation or individual and there must be no doubt over the integrity and objectivity of editorial/production teams and those who support them. For this reason there are specific constraints on those working in, or contributing to, news and current affairs output.
Those with on-air roles in BBC news and current affairs must not undertake any external activities which could undermine the BBC’s reputation for impartiality. Permission to take part in external activities must be sought from a senior management figure, such as the Head of Department, who should ensure the relevant press officer is informed about these commitments and any dates relating to publication or appearance.
In news, current affairs and factual output, contracts with on-air workers who the audience may consider to have an association or affiliation with the BBC should reflect requirements for impartiality when undertaking external activities and the need to seek approval for such activities. Contracts should make it clear that they should not, without explicit guidance from a senior editorial figure, such as a Head of Department or Editor, undertake advertising, promotions or endorsements for third parties.
Those working on consumer programmes must have no financial or business links which could influence their attitude towards any product, service or company that might be covered in their programmes. Any non-BBC activity they undertake, such as writing articles or books or chairing/appearances at conferences, must not promote or appear to promote any organisation, product or service that might be featured in the programmes they present.
Where there are additional restrictions around people working in news and current affairs output or other factual output, the general guidance will be referred to first and additional restrictions afterwards.
Public expressions of opinion
Public expressions of opinion include the use of social media and letters to the press. Where individuals identify themselves as being linked with the BBC or are primarily associated with the BBC, their public expressions of opinion have the potential to compromise the BBC’s impartiality and to damage its reputation. Because of the potential risk to the BBC’s impartiality, there are additional restrictions around those working in news and current affairs, factual output and output dealing with public policy.
Political activities
Active political involvement and commitments may give rise to conflicts of interest for people who are involved in programme making or have any editorial responsibilities in any BBC service, particularly if they deal with political or public policy issues. There is no blanket prohibition on individuals becoming involved in political activity, neither is there a single approach which applies to all activities or to all roles in the BBC. Each instance of political activity will require a judgement to be made by the relevant manager in consultation with the Chief Adviser, Politics, to whom there is a mandatory reference at an early stage if there is any possibility of a risk to the BBC’s impartiality. (See also BBC Editorial Guidelines 15.3.20)
Staff must declare any active political involvement on the Declaration of Personal Interest form. In some cases it will also be appropriate to declare the political activities of family members or other close personal contacts.
The Chief Adviser, Politics provides advice to individuals and to Divisions in order to ensure fairness and consistency in dealing with these matters.
Membership and Activity
Anyone is entitled to be a non-active member of a political party or organisation. However, there are some roles (for instance, those involved directly in political coverage) where public disclosure even of dormant membership may risk compromising perceptions of the BBC’s impartiality. In line with the Editorial Guidelines, managers or individuals should seek the advice of the Chief Adviser, Politics, where appropriate, to discuss individual circumstances.
(See Editorial Guidelines Section 15 Conflicts of Interest: 15.3.18)
Active political involvement can give rise to questions about the impartiality of the individual, the impartiality of the area in which they work and the impartiality of the BBC as a whole. Individuals should inform their manager about any political involvement so that it can be fully considered in the light of the guidance below.
There are three general considerations in each individual case:
- the type of political involvement
- the nature and seniority of the individual's BBC role
- the extent of involvement in editorial decisions, programme making and/or BBC policy.
The Type of Political Involvement
Considerations about the type of political involvement may include, for instance:
- being publicly identified as a candidate or prospective candidate for a parliamentary, assembly or local authority election; no matter that the date of the election is not confirmed
- holding any office in a party political or campaigning organisation at a national or local level
- speaking in public on matters of political controversy or public policy
- expressing or revealing views on matters of political controversy or public policy on social media, blogs, etc in books, articles, leaflets or letters to the press.
(See BBC Editorial Guidelines Section 15.3.9-15.3.10)
- canvassing for a political party or election candidate
- demonstrating practical support in the public domain for a campaigning organisation, political party or candidate, for instance, distributing leaflets, organising meetings, arranging transport etc
- promoting a partisan view on an issue put to local or national referendum.
The Nature of the BBC Role
Scrutiny of those working in journalism, including internationally, in other sensitive editorial positions or in more senior roles throughout the BBC will clearly be the most rigorous. In some cases, if they wish to maintain their level of political activity, it may be necessary to move to a less sensitive position, either temporarily or substantively, or to amend some job responsibilities, or to consider whether that activity is compatible with a continuing BBC role.
For those working outside journalism, the risk to the BBC’s impartiality may be lower, but should still be considered and agreed with their manager, in consultation with the Chief Adviser, Politics. Consideration of the risks to impartiality applies similarly to those working on air or in the public domain and to those whose roles are not necessarily publicly known. Judgements on these issues must stand up to a scrutiny which assumes any individual’s role may become publicly known.
The Type of Programme
News and current affairs programmes for international, national, regional and local output, as well as any factual output dealing with public policy issues, are subject to the most stringent tests of impartiality. For other types of output, including lifestyle, factual (except those dealing regularly with public policy issues) and entertainment, considerations may be less stringent, but the managers will need to consider the implications in individual circumstances and may consult the Chief Adviser, Politics.
Elections - Seeking Nomination or Declaring Independent Candidacy
Individuals seeking nomination need to consider from the outset whether an elected position is compatible with their substantive role and the possible consequences for their own and the BBC’s impartiality. Anyone who intends to seek nomination as a candidate for election at national or local level – or intends declaring publicly their independent candidacy - should notify their manager at the earliest opportunity, so that the implications can be discussed with the Chief Adviser, Politics.
An individual selected as a candidate must notify their manager, who will inform the Chief Political Adviser. Any individual (for instance, someone joining the BBC) who holds an elected position in Local Government at any level must ensure that their manager is notified. The manager must inform the Chief Adviser, Politics.
For anyone working in News or Current Affairs, or on Factual output involving public policy issues, who decides to seek nomination as a candidate, or declares their candidacy, it may be necessary to transfer them immediately to a less sensitive role. In these circumstances, the individual must be placed in gainful employment and not sent home on paid leave.
It will be the responsibility of the Director of the relevant Division or their nominee to ensure a suitable temporary alternative role is found at the earliest opportunity. The Director’s primary responsibility, however, is to ensure impartiality and they will, therefore, have discretion to place the individual in whatever temporary role they deem suitable. If the individual’s candidacy is likely to be long term, or repeated, or they are successfully elected (for instance, to a role in local government), then the Director may decide that this is incompatible with a continuing substantive role in the BBC.
Elections - Candidates
Once an individual has been selected as a prospective candidate, at national or local government level, they may not engage in programme work which could be linked to political or public policy issues, even if the date for the election has not been confirmed. Prospective candidates campaign actively to obtain support, and as such become the focus of public attention. This also applies to any individual making a public declaration of their intention to stand as an independent candidate.
Even for those working outside news and current affairs, or Factual output dealing with public policy issues, it is unlikely that they will be able to undertake high profile or public programme responsibilities until after the election. Managers may need to consult the Chief Adviser, Politics, to ensure that prominence on BBC output does not lead to a reasonable perception that it is benefitting an individual’s candidacy.
When BBC employees stand for election to a full time political role (eg the UK Parliament, the devolved legislatures, or an executive mayoralty), they may take unpaid leave of up to six weeks for the period to the election date. The leave is unpaid in order to avoid any suggestion that the BBC is subsidising the individuals' election campaign. If a candidate continues to work during the election period, it is imperative that they are employed in a role where there can be no perception of a conflict of interest and that they could not be seen as campaigning during BBC time.
Individuals may stand for local government elections provided there is not a conflict of interest with their BBC duties. They will be expected to conduct their campaign activity in their own time and ensure that nothing they say in public could be perceived as compromising the BBC’s impartiality.
Presenters and regular contributors who are candidates for elections should not appear in any programmes in their normal roles during election campaigns or, in some circumstances, even before the formal election period, if that caused any actual unfairness to other candidates. They may, of course, contribute as candidates according to the relevant election guidelines regarding candidates’ appearances.
If a family member or close personal contact is standing for election, it is acceptable for an individual to express personal support, but there should be no use of the BBC's name or (for those in roles requiring impartiality) expression of political support; the individual should declare the interest and must not fulfil any BBC role with any direct connection to the candidacy of the family member or contact involved.
Elections – Afterwards; Successful and Unsuccessful Candidates
If individuals are unsuccessful in seeking nomination or decide not to pursue their
candidacy, they may return to their original substantive job. However, their Director may need to consider if there are any reasons regarding the BBC’s impartiality, or the conduct of the candidate, which mean the individual may not be able to return immediately or at all. In the event of such a decision becoming necessary there will be full discussion of the issues with the individual concerned and the advice of the Chief Political Adviser will be sought to ensure consistency.
If an individual is elected to (and takes up) a full time role (e.g. in the UK Parliament, the devolved legislatures, or an Executive mayoralty) they will be required to resign from the BBC immediately.
If an individual is elected to a part-time position in local government, they may continue to work for the BBC. However, (with the possible exception of those elected as independents at the level of parish councils) they are unlikely to be able to fulfil a journalistic or editorial role in news and current affairs involving international, national, regional or local output, or any factual output dealing with public policy issues.
Non-political voluntary public office
Non-political and voluntary roles in public office may be acceptable even for editorial staff in news programmes. This includes school governorships and being a magistrate. However, content producers should be careful in fulfilling these roles about involving themselves in controversial matters of public policy related to organisations which campaign on political or public policy issues and should seek advice from the Chief Adviser, Politics. They may have to declare potential conflicts of interest and be unable to take part, in their BBC role, in any directly connected output.
Charities and campaign work
Apart from the BBC’s own charities and charitable trusts and other specific appeals carried on BBC services, the BBC takes care not to be seen to endorse particular charities.
The Editorial Guidelines require that any proposal by individuals to work for, or be publicly associated with, charities and campaigning groups must be referred to the head of department, who must consult Editorial Policy.
BBC figures are usually asked to take on public roles connected with charities primarily because of their association with the BBC and any activity associated with the charity might be perceived as BBC endorsement. If BBC people take on a public role for a charity, the BBC may be considered to be advantaging one charity over another, and this may be seen to compromise our principles of fairness and impartiality.
Special care should be taken with invitations to take part in public appearances, to speak publicly or to chair conferences that are related to charities, particularly if they are known as campaigning organisations. No impression should be given of BBC endorsement of one charity over another.
Charities and Campaign work – Additional Considerations in News and Current Affairs and Factual and Consumer Output
Those working in news and current affairs, factual and consumer output should not normally associate themselves with any campaigning body, particularly if it backs one viewpoint in a controversial area of policy.
The Editorial Guidelines require that news and current affairs presenters should not front campaigns for charities or campaigning bodies as this could compromise the BBC’s reputation for impartiality and that any proposal that would not comply with this must be referred to Director Editorial Policy and Standards.
Assessing the Suitability of Charitable Involvement
When assessing proposals for involvement with charities, managers should ensure that BBC editorial staff, BBC correspondents on non-staff contracts and freelances, known to the public primarily as presenters or reporters on BBC news or current affairs programmes, do not:
- Endorse charities which are advocating a particular standpoint on matters of political controversy or public policy, as the BBC needs to be seen to represent all sides of an argument fairly and accurately
- Associate themselves with a charity which is closely involved in an area of activity about which they are likely to report
Except in relation to BBC appeals, such as Children in Need, or appeals carried by the BBC, they should not:
- Appear in an advertisement for any charity
- Appear in charity fundraising appeals or in publicity for fundraising eg large-scale mail-drops
- Front charity campaigns
- Be the public spokesperson for a charity
- Undertake media interviews on behalf of a charity
- Advise a charity on how to lobby or present itself in the media
Those working in news and current affairs or factual or consumer output may be asked to undertake public roles such as ambassadors or patrons of charities. In some cases, for example where they have a specific personal experience, it may be acceptable to undertake such roles, but not if they involve any of the activities listed above. Careful consideration needs to be given as to when such roles might be acceptable. In many cases, being an “ambassador” would be inappropriate as it normally involves campaigning for a charity.
The role of patron indicates a high level of endorsement and may not be suitable. Chairing a charity probably involves even more involvement and is unlikely to be acceptable. Being a trustee may be less sensitive, but consideration needs to be given to the fact that trustees are usually involved in ensuring the probity, good conduct and good management of a charity.
However, on rare occasions those in news and current affairs may have a closer involvement with a charity involved with the health, safety and wellbeing of journalists or some other charity connected to their role or experiences. In line with the Guidelines, Editorial Policy must be consulted about any such proposals and approval must be obtained from the head of department.
Local Involvement with Charities
In some cases, with the permission of the relevant head of department, it may be possible for News and Current Affairs people to be involved more closely at a local level with charities which are not concerned with lobbying on matters of public controversy, as long as this does not compromise their impartiality or the BBC’s impartiality and that they are not involved with an organisation on which they are likely to report.
Activities Connected to BBC charities and Appeals Carried by the BBC
BBC staff and presenters may take part in programming and events to support BBC Children in Need, Comic Relief, and other BBC fund-raising appeals or cross-BBC charitable initiatives. BBC Global News staff and presenters may have involvement with BBC Media Action.
Presenters may, where appropriate, present emergency appeals carried on BBC services and in some cases they may present a specific charity appeal carried by the BBC, such as the Radio 4 Appeal or Lifeline, providing the association with the particular charity does not compromise their impartiality or the impartiality of the programme they present.
In a case of a major emergency, BBC licence fee funded services may carry appeals by the Disasters and Emergency Committee (DEC).
None of this charitable output should give the impression of campaigning on an issue of political or public controversy.
(See Guidance: Charity Appeals)
Writing Commitments
It is a requirement of the Editorial Guidelines that all proposals to undertake external work, including writing books or articles for newspapers, magazines or websites, or publishing podcasts should not risk compromising the impartiality or integrity of the BBC or its content, or risk damaging the reputation of the BBC.
BBC managers must judge what is appropriate and may consult Editorial Policy where necessary. The extent to which an individual’s external writing or podcast commitments may need to be constrained will depend on the following factors:
- the nature of the output they are involved with
- the individual’s role in that output
- the nature or subject of the written work or podcast
- the nature of the publication or platform where it will appear
- any sensitivities over timing – for example, if the timing of publication makes a subject more controversial or if it coincides with the transmission of BBC output in a way that increases sensitivities
Writing/publishing Commitments - One-off Articles/Podcasts and Regular Columns
It is a requirement of the Editorial Guidelines that proposals to undertake writing commitments about controversial subjects must be referred to a senior level in the relevant division. Copy approval will be needed for all columns and any one-off articles or podcasts related to topical or controversial issues. In general, there will be less concern where the subject of the work is not controversial and is unrelated to the subject that is associated with the individual in their work for the BBC.
If the article or podcast is about the BBC, the programme on which they work, subject matter clearly relevant to the editorial area in which they work, or any other subject which could give rise to concerns about conflicts of interest, a senior editorial figure, such as the head of department, would normally ask to approve the copy in advance. Editorial Policy may be consulted
Any proposals for editorial staff to write regular columns or publish regular podcasts should be referred to a senior editorial figure who will decide what is appropriate in their area.
Regular presenters on long term contracts should discuss the range of their journalistic commitments with the relevant Head of Department who will consider if there are any areas of activity which might lead to a conflict of interest. In some cases they may be contractually obliged to consult the BBC about writing commitments. BBC copy approval would normally be required for any article or podcast about the programme they present. The Head of Department may also ask for copy approval for articles or podcasts of particular sensitivity connected to the subject matter of the programme.
In some areas, such as sport, regular presenters or “pundits” may write articles or regular columns about the subject matter of their programmes. Heads of Department must judge the suitability of such work and whether there is any need to ask to see such articles before they are submitted for publication.
Presenters or contributors who present programmes for the BBC only occasionally, or for specific series, may undertake a range of writing commitments. However, the Head of Department should discuss with them any areas of activity which could give rise to a conflict of interest and ask to clear articles in advance if they are about the programmes they are involved in.
Writing Commitments – One-Off Articles and Regular Columns Relating to Sport
Columns on sport often deal with issues of public controversy. For this reason, individuals wishing to write columns about sport, whether regular or one-off, will need the approval of their Head of Department (including copy approval). Such columns should not focus on any political or business controversies associated with Sport and any reference to such matters must be duly impartial.
The Director BBC Sport and the relevant BBC News Head of Department will decide what may be appropriate for BBC Sport News journalists. Editorial Policy should also be consulted. If, in exceptional circumstances, approval is given for a regular column on sport, the BBC must approve all copy in advance.
Writing/publishing Commitments – Additional Requirements in News and Current Affairs
It is a requirement of the Editorial Guidelines that individuals working in news and current affairs cannot undertake regular writing commitments about controversial subjects.
In some cases, individuals working in news and current affairs may write regular articles or columns or publish podcasts for external publications on a specific non-controversial topic such as gardening or music. Columns/podcasts should not deal with any public debate related to the subject matter and it is important that nothing which is published compromises the BBC’s reputation for impartiality. Articles and podcasts should not refer to issues which they are likely to cover on air. A senior editorial figure will require BBC copy approval for any such articles or podcast. Articles and podcasts must be submitted for approval in good time before the publication deadline and the senior editorial figure must inform BBC Press and Publicity.
In some cases, with the prior written approval of a senior editorial figure, such as the relevant Head of Department, a one-off article for an external publication may be written on a matter relating to:
- News, current affairs or politics
- Economics, business or finance
- Current political or public policy debate
- Media issues
- Moral or ethical issues or religion
A senior editorial figure will require BBC copy approval for any such articles. Articles must be submitted for approval in good time before the publication deadline and the senior editorial figure must inform BBC Press and Publicity.
BBC staff require prior written approval from a senior editorial figure, such as their Head of Department, to publish a book on any topic. The senior editorial figure should consider the sensitivities in that area and whether the book could give rise to a conflict of interest or raise concerns about the integrity or impartiality of the BBC.
If publication goes ahead, they must judge whether the subject matter is such that the copy should be approved by the BBC before publication.
Presenters and regular contributors to the BBC on long term contracts should inform the relevant Head of Department in advance about any proposal to write a book about the BBC or their work for the BBC or about the programme in which they appear. In some cases, contracts would require such presenters and contributors to ask for permission from the BBC to publish any such book. The copy of any book about the BBC or a BBC programme must be cleared before publication by the relevant Head of Department. The copy should be submitted in good time before publication.
Whatever the subject matter, presenters should not use their programmes as a vehicle for promoting books they have written. In some cases, it may be editorially justified to make some reference to the book, providing there has been clear prior approval from the editor or relevant editorial executive. But it is essential that the book is not "plugged" on-air.
Writing Books - Additional Requirements in News and Current Affairs
Any book written by those working in news and current affairs must be approved by the BBC and a copy should be submitted in good time before publication to the Head of Department or their nominee. The relevant BBC Press and Publicity Manager should be informed of plans to promote and market the book. Editorial Policy may be consulted.
Individuals will need prior permission from the relevant Head of Department for the granting of any serialisation rights, in respect of any books written in accordance with this guidance.
Approvals and related marketing should be discussed with the relevant Press and Publicity Manager. With the prior approval of the BBC, individuals may undertake promotional activities for books they have written. Any such activity must not jeopardise the individual’s reputation for objectivity and impartiality.
Public Speaking and other Public Appearances, including Chairing Conferences
No public speaking commitments or other public appearances, such as chairing conferences, or speaking at conferences should compromise the authority, impartiality or integrity of presenters or editorial staff working on BBC output. Any such commitment should not imply BBC endorsement of any product or service nor imply support for any charity or campaigning organisation. A senior editorial figure, such as a head of department, should discuss any outside commitments with editorial staff and presenters in order to make a judgement as to whether activities are appropriate.
Additional Requirements in News and Current Affairs, including Sports News, and in Factual and Consumer Output
Individuals in news and current affairs will need written permission from a senior editorial figure, for example the Head of Department, before undertaking any outside public appearances, including speaking at or chairing conferences. They must not make any appearances which are promotional for a third-party commercial concern and nothing they do or say should undermine the integrity or impartiality of the BBC. They should not allow the use of the BBC’s name or brands in connection with marketing for a public appearance unless this has been approved by the BBC. The onus is on the presenter or reporter to inform the BBC about the overall range of work they undertake and about any particular commitment which may be controversial or may lead to problems concerning perceptions of impartiality.
Special care should be taken with appearances related to charities, particularly if they are known as campaigning organisations.
Presenters in factual areas should not chair conferences which are designed to promote products or services directly related to the subject matter of the content or output on which they work/appear.
Those working on consumer programmes must have no financial or business links which could influence their attitude towards any product, service or company that might be covered in their programmes. Public appearances, including chairing/appearances at conferences, must not promote or appear to promote any organisation, product or service that might be featured in the programmes they present.
Those working in news and current affairs must remain impartial, in line with the Editorial Guidelines. If, during a public appearance, a viewpoint expressed turns out to be controversial or one-sided, editors should consider whether to allow the presenter to cover the issue on-air.
There are specific issues in relation to impartiality and the perception of impartiality if anyone from BBC news and current affairs, including sports news, is included on an advertised agency list as being for hire for public speeches and events. Individuals must not sign up with an external agency for public speaking without the written permission of the relevant Head of Department.
BBC Global News
BBC Global News Ltd is a commercial concern and BBC World News presenters may take part in some promotional events or chair conferences which are organised by BBC World News or in conjunction with others, or which are organised by third parties.
Where their involvement is part of their contractual commitments to the BBC, see Guidance: Use of BBC Brands by BBC Global News for Marketing Events.
Where presenters, correspondents or reporters are being engaged independently of their existing commitments to the BBC (eg through their agent), they are subject to this Guidance.
Personal and Outside Interests
Commercial, Business and Financial Interests
The personal commercial, business, financial and other outside interests of those working for the BBC must not compromise their BBC role and, in line with the Editorial Guidelines, these interests must be declared on the Declaration of Personal Interests form.
Individuals, including presenters and on-air talent, must declare any commercial or other relevant outside interest that may affect their on-air role or that is connected with the subject matter of the content that they presenter or appear in. This declaration must be made before the signing of any BBC contract.
In some cases, particularly for on-air contributors to journalistic or factual programmes, commercial interests, including significant shareholdings, may be deemed incompatible with their BBC on-air role. Some contributors, who are not necessarily presenters, may play a sufficiently significant role in content that the BBC may decide that they need to be subject to the same restrictions as other presenters in that genre, and must declare any commercial or other relevant external interest which may impinge on their on-air role. This may include regular panellists, pundits and programme judges.
Those working on consumer programmes must have no financial or business links which could influence their attitude towards any product, service or company that might be covered in their programmes.
There are additional editorial and legal requirements for those working in financial output, these are outlined on a separate page.
Specialist Music
In specialist popular and classical music content some presenters or freelance producers have been engaged by the BBC for their expertise and knowledge of the industry. Such talent may have links with artists and the music industry. They may themselves be recording artists or music or events/festival producers. Therefore particular care needs to be taken with regard to commercial or external interests.
Managers within the relevant division will need to put in place suitable editorial safeguards to ensure that those working in these areas declare all relevant external interests. It is important to ensure those interests cannot unduly influence editorial decisions, such as choice of music/ artists included in their programmes. Playlists should be regularly reviewed to ensure that the music and artist guest choices stand up to editorial scrutiny. In line with the Editorial Guidelines, these arrangements must be referred to Editorial Policy.
Personal Benefits
In line with the Editorial Guidelines, under no circumstances should anyone working for the BBC or on behalf of the BBC receive personal benefits from suppliers or accept goods or services as inducements.
There are specific restrictions on the acceptance of clothing, products, services or equipment by BBC staff, on-air contributors, reporters and those who present or regularly appear on BBC content. Some contributors, who are not necessarily main presenters, may play a significant role in a programme or series. In such cases the BBC may decide that they need to be subject to the same conditions as presenters.
Any third-party arrangements to promote clothing, products, services or equipment must be declared to the BBC. This is so that content makers /commissioners /BBC managers have all relevant information and can ensure that such goods and services do not appear in/are not referenced in content inappropriately or inadvertently. In particular, unless it is approved product placement on a BBC Commercial Service, the following principles should be applied;
- Clothing or equipment must never be accepted free or at reduced cost in exchange for using it on air or with any understanding that it will be shown, referenced, or used on air
- Any clothing or equipment which has been accepted free or at reduced cost must not be worn or used on air or in content related marketing and promotions, nor should it be worn if it is received at a reduced cost from specific manufacturers or designers
- Presenters or other individuals must not appear on-air wearing clothing or using products or services which they have agreed/been contracted to promote, advertise or endorse or in which they have a specific financial interest
- Equipment which has been accepted free or at reduced cost should not be used or shown on air.
(See also: Lifestyle Content)
On-air talent – Commercial Advertising, Promotions and Endorsements
This section outlines additional considerations around the external promotional work that may be undertaken by those who “front”, “anchor” or make a significant presenting contribution to BBC output in any genre. It applies to all BBC presenters and regular on- air contributors. Promotional activity, which includes commercial advertising and endorsements, including work for BBC Commercial Services, must not risk damaging the integrity of the BBC content they are associated with, or risk damaging the BBC’s reputation generally.
(See Editorial Guidelines Section 15 Conflicts of Interest 15.3.34-15.3.39)
An assessment of whether advertising or promoting third parties is acceptable will be made by the relevant Head of Department responsible for the output, in consultation with Editorial Policy and the senior Business Affairs Manager. Decisions will be made on a case by case basis, however, in addition to the considerations set out in the Editorial Guidelines, the following principles apply:
- Promotional activity must not compromise the reputation or integrity of the BBC or the values of any BBC brand
- The nature of the individual’s on-air role will affect what is appropriate
- Key presenters who have long standing associations with the BBC may be subject to particular restrictions on their promotional activities
- Where the individual is not involved in news and current affairs or other journalistic output, there will be fewer restrictions on their off-air activities – however the off-air activity should not compromise their integrity or the integrity of the content they present
- There may be fewer restrictions on on-air contributors who are seen as independent experts or who only present a few programmes or a one-off series
- There must be no conflict of interest between the on-air contributor’s BBC role and the promotion or endorsement of a particular product or service
- Individuals should not replicate their on-air role to endorse a product, service or organisation either in general advertising or on any personal or third party website. Their external activities must not reference the BBC or its content directly or indirectly
- No product, service or organisation promoted by on-air contributors may be shown, featured, reviewed or discussed in the BBC programmes they present
- Contributors may be permitted to undertake promotional work in relation to a book they have written, in line with this guidance on writing books.
Unsuitable Products or Services
In line with the Editorial Guidelines, there are some products or services that on-air talent should not promote – such as tobacco products, adult products and services and weapons. Other products or services are also sensitive and will require careful consideration in order to avoid damaging the BBC’s reputation, for example, promotional work for alcohol, high-interest financial products and gambling.
Advertising/Promotional Commitments and Editorial Integrity
When engaging on air contributors, consideration should be given as to whether their existing advertising /promotional commitments are likely to compromise the BBC’s editorial integrity.
Timing of Advertisements/Promotions
We should consider whether sensitivities arise around the timing of an advertising campaign in relation to the scheduling of BBC content – especially at launch. The BBC may decide that such advertising or promotions are only acceptable if there is a suitable time period between the advertising campaign and the start and finish of the first BBC transmission of these programmes and any related BBC marketing activity.
Some on-air contributors are only contracted to the BBC for specific time periods to coincide with the preparation and filming of the series of programmes in which they appear. However, as far as possible, contractual safeguards concerning advertising should also cover the periods when content is to be transmitted. We should additionally consider whether output will be available on demand, and whether that will affect what promotional work is appropriate.
Additional Considerations – News and Current Affairs (including Sports News), Consumer and Factual Output and Business Output
In line with the Editorial Guidelines, on-air talent on news, current affairs and business programmes are not permitted to take part in any promotional activity for third parties.
Presenters and reporters in factual output that covers matters of public policy, or political or industrial controversy are not normally permitted to take part in any advertisements for third parties. The degree to which they are regarded as objective journalists in their BBC on-air role will affect decisions as to whether any outside promotional work is permissible.
The key consideration for those working in factual output will be whether the external promotional work could undermine their on-air BBC role. Where those working in factual output are considering taking on promotional work, this should be considered by the relevant Head of Department who may consult Editorial Policy.
Additional Considerations – Lifestyle Programmes
These are non-journalistic programmes which do not undertake specific consumer reviews, but may sometimes give “how to” advice or information about what ingredients or types of goods to use. Areas of lifestyle programming include makeovers, gardening programmes and cookery shows.
The degree to which such advice is offered will affect the on-air talent/presenter’s ability to undertake promotional activities. The following principles apply:
- Lifestyle presenters, including chefs and cooks and judges, may normally undertake advertisements and promotions, in any medium, for products which are not directly associated with the subject matter of their programmes. However, these advertisements must not replicate their on-air role, reflect the programme or BBC content or undermine their BBC role.
- Lifestyle presenters who give specific advice on what types of products to buy or use should not undertake any advertising for those types of products.
- Presenters who give specific advice on how to solve problems should not advertise or promote products or services which aim to solve those problems
- No lifestyle presenter should undertake radio, online or television advertising for a product or retailer directly associated with the subject matter of their programmes.
- Lifestyle presenters who do not give any specific advice on what to buy or use may undertake adverts or promotions for retailers who sell products connected to the subject matter of their programmes. Such adverts for retailers should not promote any particular branded or own brand product or service, if that type of product or service is covered/used in the programmes they present.
Cookery Programme Presenters
- Presenters/judges of BBC cookery programmes including chefs and cooks should not undertake radio or television advertising for any product, equipment or retailer directly associated with the subject matter of their programmes
- Presenters of BBC cookery programmes who give specific advice on-air about how to cook and/or which ingredients or specific equipment to use should also not undertake any advertising for specific branded food products or equipment
- If presenters do not give specific advice on equipment, they might in some cases be permitted to advertise equipment, as long as the advertisements do not in any way replicate their on-air role and such equipment is not shown or featured in the programmes they present. Such proposals should be considered by the relevant Head of Department who may refer to Editorial Policy
- Presenters of cookery-related content, which does not give specific advice on how to cook or which ingredients or equipment to use (e.g. travel shows about cookery, entertainment cookery gameshows, competitions or talent searches) may:
- advertise food retailers off-air. Such advertisements or promotions must not make any reference to their BBC programmes or refer to their on-air BBC role. Nor should they promote specific branded food or ingredients
- all such advertisements must be approved by the relevant Head of Department who may consult Editorial Policy and care will need to be taken around the timing of such advertisements
- advertise kitchen equipment off-air as long as this is not shown in their BBC programmes.
Presenter’s Own Products
Lifestyle presenters such as cooks and chefs, gardeners and designers often develop their own or have pre-existing products which may be associated with the type of content they present. Some may distribute products through their own websites and social media channels. Presenters and on-air contributors on long term contracts must inform the BBC about any pre-existing products/services, or those they are developing to ensure the BBC can manage the conflict of interest.
The onus is on the presenter to inform the BBC prior to entering into a contractual agreement in relation to their products. The presenter’s own products, or those closely resembling them, must not be shown, used or referred to in any of their BBC content.
Advertising and Marketing of Presenter’s Own Products
Any promotion of such products needs to be treated with care to ensure that the presenter’s on-air role is not undermined. Advertisements on television or radio must not replicate the presenter’s on-air role and must be referred to the BBC in advance to ensure that such advertising campaigns do not cause such issues
In many cases lifestyle presenters may be able to advertise their products in newspapers, magazines, on billboards or online on social media channels, providing they do not use or feature these products or ones closely resembling them in their programmes.
Such advertising or marketing promotions must not replicate the presenter’s on-air role or make reference to their BBC programmes.
Point of sale promotions and promotions on the presenter’s own website/social; media channels may be acceptable. However any such promotions must not reference their BBC connections and no material from their BBC programmes may be used. If the presenter’s social media channels /websites sell branded products such arrangements should be discussed with the BBC and Editorial Policy may be consulted.
Sport
Presenters, reporters, commentators and regular “pundits” who work on BBC sports coverage and sports programmes should not advertise products or services connected with the sport or sports which they cover nor should they undertake adverts for the sponsors of the sports which they cover. It may be acceptable for them to advertise products or services which are unconnected to the subject matter of the programmes in which they appear, provided that their perceived connection to the product does not damage the BBC’s reputation or the BBC brand. The advertisement should not replicate their on-air role. They should not appear in an advert with any other on-air talent with whom they appear on-air in BBC content. In some cases presenters and commentators (particularly former sportspeople) may be contracted for a short period for a specific tournament. Care should be taken to ensure that they do not undertake any advertising while working for the BBC which could appear to compromise their impartiality.
Presenters and Regular Panellists of Sports Quizzes and Sports Entertainment Programmes
Presenters and regular panellists of sports quizzes and sports entertainment programmes should not undertake any advertising which would undermine their on-air role.
BBC sports journalists who report for BBC news programmes are subject to the same restrictions as other BBC news journalists and may not undertake any commercial advertising. Any proposed exceptions must be referred in advance to BBC Sport management who must consult Editorial Policy.
Children’s Programmes
The BBC is a trusted provider of content for children. As such, presenters of BBC children’s content may be seen as role models and any off-air activities must be carefully considered to ensure they are compatible with their on-air BBC role. In addition to the requirements of the Editorial Guidelines, presenters must not undertake promotions for goods, services or organisations that would be incompatible with their on-air role as a BBC Children’s presenter or compromise their objectivity.
Any proposal for a BBC Children’s presenter to undertake advertising or promotions must be referred in advance to Director BBC Children’s who should consult Editorial Policy.
Entertainment/Factual Entertainment
On air contributors, including presenters, panellists and judges, should not appear in adverts which are closely associated with the subject matter of their programme or which mimic the style of the programme. Advertisements must not be incompatible with their on-air role, damage the BBC brand or bring the BBC, the contributor or their programmes into disrepute.
References to BBC content in Advertisements
Any advertisement/promotion in which BBC on-air talent appears should not copy or “make play” of BBC content. No impression should be given that the BBC is endorsing any commercial product or service. The style of the advertisement should not bring the BBC into disrepute. The following principles should be observed:
- Adverts should not replicate or “pass off” the role the on-air contributor plays in the BBC content
- Adverts should not replicate editorial elements of content
- No music or graphics associated with the BBC programme should be used
- Adverts should not replicate the look or style of the BBC content .
- There should be no use or direct imitation of BBC programme sets or the key elements that are associated with look and feel of the programme
- No adverts should refer to the BBC or any of its services or programmes.
Normally no more than one presenter from any BBC programme should appear in the same advertisement or promotion. This is to avoid any suggestion of a connection between the BBC programme and the advertisement. However in certain circumstances in entertainment or lifestyle programming on-air talent may have already established themselves as a duo or group act, independently of their BBC role, In these cases consideration may be given as to whether they may undertake joint advertising and promotions. Any such proposals must be referred to the relevant Head of Department and Editorial Policy.
Voiceovers
BBC on-air talent may sometimes feature as voiceover artists in television and radio advertisements. The restrictions are the same as for all advertisements in relation to what, if any, advertisements talent may undertake, the products and services which may be promoted and the nature of the advertisements.
They should not refer to the BBC or their BBC programmes and the advertisements should not replicate their on-air role. For example, a BBC football commentator should not conduct a voiceover in the manner of a match commentary. They should not undertake advertisement voiceovers for products or services they are likely to review or might select for inclusion on a BBC programme. For example, presenters of BBC music programmes should not do voiceovers in advertisements for music releases where they are involved in selecting those releases for inclusion in the programme or station output.
Actors and Artists Who Perform in BBC Content
In addition to the requirements of the Editorial Guidelines, normally no more than one actor/performer from a current BBC series may appear in an advertisement if such an appearance may lead to the perception of a connection with the BBC. Some BBC productions have specific restrictions in contracts with such contributors.
In some cases careful negotiations may need to be held where performers hold the rights to characters which are used in BBC entertainment, comedy or other programmes. In such cases consideration should be given to the timing of advertising campaigns in relation to the transmission periods of the programmes shown by the BBC.
Talent or Agent owned Independent Production Companies
In addition to the requirements of the Editorial Guidelines, there will be particular risks where on air talent is also in effect the employer of the production team due to the ownership arrangements of the production company. Special measures will need to be put in place to mitigate these risks.
Agent owned production companies (or where the agent is a significant shareholder or is on the board of the company), should not be commissioned to produce factual programmes about the talent they represent.
The Talent cannot be the overall executive producer, there should be a separate overall executive producer who is responsible for the content.
Factual Programmes
Talent owned production companies should not normally be commissioned to make BBC factual programmes where the talent is the subject matter of the programme or is featured in any significant way. Where output has been commissioned in accordance with the Editorial Guidelines, the commissioning team should ensure objectivity is achieved by:
- Putting in place executive production on behalf of the BBC
- Ensuring there is an active BBC role in all stages of the programme’s production, from research to the final edit
- Ensuring that referrals are made to Editorial Policy throughout the process in case of any difficulty
When commissioning teams receive proposals for factual programmes concerning BBC talent from another genre (for example, a factual commission about a sports personality), they should seek advice from that genre on any connections between the independent producer and talent which could provide an editorial conflict of interest.
Entertainment, Factual Entertainment and Music Programmes
It may be possible for some entertainment, factual entertainment, and music shows to be commissioned from agent or talent owned production companies where the Talent is to be used as the presenter, star of the show or regular contributor. Such proposals must be approved in advance by the relevant Head of Department who may consult Editorial Policy.
In these circumstances, we must ensure that the BBC maintains overall editorial control over all stages of production, so that:
- commissioning teams actively review guests and their associated products featured on agent-owned or talent-owned independent productions
- guests from associated talent agencies are always editorially justified
- records are kept of all guests on programmes produced by agents or talent
- owned independent production companies and checked with the agent’s client-list to ensure editorial independence
- we should avoid a cumulative promotional effect
- measures may be required such as a log of playlists etc to manage any perception of a conflict of interest
Drama and Comedy Programmes
Where talent is to feature in content made by talent or agent owned production companies, such proposals must be discussed in advance with the relevant Head of Department who may consult Editorial Policy. Talent may bring ideas, content and formats to the BBC and write the content as well as star in it. There must be a separate overall executive producer in all such cases.
Last updated November 2020