Declaration of Personal Interests
4.4.1 All individuals engaged by the BBC are required to declare any personal interests which may affect their work with the BBC. These should be set out on a Declaration of Personal Interests form and it is the responsibility of individuals to ensure it is maintained and is up to date. Potential conflicts can normally be managed and individuals should discuss them with their line manager to evaluate the likely implications for their BBC role and any required mitigations.
Most freelances are also asked to declare any external or commercial interests which may impinge on their work with the BBC. Independent producers should make a declaration at the time of commissioning.
Mandatory Referral: Where there is a material connection between anyone who has a role in the creation of BBC content with products, businesses or other organisations featured or reflected in that content Editorial Policy must be consulted in advance.
External interests – both commercial and non-commercial – of presenters and other on-air individuals with an on-air role closely associated with a programme such as a judge, host, regular panellist etc could lead to a conflict of interest. When contracts are negotiated, such individuals must declare any commercial or other external interests that may have a bearing on their on-air role or which are connected with the subject matter of the programme they present.
Significant financial interests should be declared by all production and editorial staff working for the BBC if they are in any way connected with the area in which they work or the subject matter they cover.
The area of greatest sensitivity is financial journalism where additional legal requirements apply in terms of what must be declared.
(See guidance: Conflicts of Interest)
4.4.2 The onus is on individuals to inform their managers about any outside interests they have, so that the BBC can decide what action is needed in response to any perceived conflict of interests. In some cases, this can also apply to an individual's family and/or close personal contacts.
4.4.3 Some non-political voluntary public roles, such as school governor or magistrate, are normally acceptable even for those involved in editorial decision making, including in news and current affairs output. These roles should be declared.
Editorial Policy may also be consulted.
4.4.5 Increasingly people who work for and with the BBC may be looking to diversify their external interests, so may not work solely for the BBC, even if their post is deemed to be a full-time one. Depending on the area of the BBC an individual is engaged in, such portfolio careers may constitute a conflict of interest. Care must be taken to ensure that external roles are clearly delineated and signposted, as appropriate, so that the audience is clear in what capacity a person is operating. The individual's contractual position may also need to be checked.
Mandatory Referral: Where people who work for the BBC develop portfolio careers involving external roles, early referral to a senior editorial figure is required.
Editorial Policy may be consulted.
Risks of Conflicts of Interest
4.4.6 There are four principal areas of potential risk that may arise from an individual's external interests and activities. These risks exist across all content areas:
- the risk of bringing the individual and/or the BBC into disrepute
- the risk of bringing the individual and/or the BBC's impartiality into doubt
- the risk of bringing the BBC's independence into doubt
- the risk of an individual's commercial interests, promotional work, external activities and other interests compromising their own and/or the BBC's integrity.
Later in the section is a list of external activities that may give rise to conflicts of interests, information about the potential risks that may arise and the restrictions that may be required in different output areas. For most activities there is general advice followed by specific advice for those working in news and current affairs and factual output.
All output areas
4.4.7 The external activities of those responsible for commissioning or producing content for the BBC, and of on-air talent must not risk damaging the BBC's reputation. An individual's off-air connections with charities, campaigns, political parties or other organisations must not risk bringing the BBC's impartiality or integrity into doubt. Where individuals may be restricted in their off-air activities and interests because of the nature of their role with the BBC, this is set out below in External Activities.
4.4.8 People involved in making or presenting content for the BBC risk compromising the integrity of their BBC output by off-air involvement in inappropriate commercial interests.
4.4.9 The Guidelines are not intended to prevent individuals with expertise having established and appropriate commercial relationships in their field.
Mandatory Referral: In some areas – such as specialist music, arts, sport, science or lifestyle programming – on-air talent, commissioning and production staff, and other teams who support them, may have commercial, professional and external personal interests in their area of expertise. In such cases, the relevant division should ensure that appropriate editorial procedures are in place so that there is no conflict of interest with their BBC role. Editorial Policy must be consulted.
News and Current Affairs and Factual Journalism Output
4.4.10 News and current affairs output may deal with any issue, cause, organisation or individual and there must be no doubt over the integrity and impartiality of editorial teams. For that reason, there are additional constraints on those involved in the production and presentation of BBC news and current affairs output.
These restrictions safeguard the BBC's impartiality and protect individuals involved, who may face accusations of bias.
4.4.11 There are also significant restrictions on the external and commercial work that it is appropriate for individuals working in news and current affairs to carry out. These restrictions are set out below in External Activities.
These restrictions also apply to areas of factual output which consider matters of current public policy or political controversy on a routine basis.
Financial Journalism
4.4.12 There are additional requirements of, and legal constraints on, financial journalists. People working on financial programmes for the BBC should register their shareholdings and other financial interests or dealings. It is illegal to use financial information acquired in advance to trade ahead of the markets. It is also illegal to promote financial services without proper authorisation from the relevant regulatory authorities. Further information is in the Conflicts of Interest guidance.
External Activities
4.4.13 External activities which may give rise to a conflict of interest include, but are not limited to:
- public expressions of opinion, including on social media
- political activities
- charities and campaign work
- writing and other broadcast commitments in all media
- public speaking and other public appearances
- academic roles
- media training
- personal benefits
- on-air talent and promotional activity, including commercial advertising and endorsements
- references to BBC content in advertisements or promotions and actors replicating their BBC roles in external output
- external activities by regular contributors to third-party output, including social media influencers
- presenters of news and current affairs and factual journalism output appearing in drama
- talent or agent-owned independent production companies.
Public Expressions of Opinion, including on Social Media
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Section 2: Impartiality and guidance: Personal Use of Social Media
4.4.14 Where individuals identify themselves as being linked with the BBC, and are content makers in on-air or off-air roles or are presenters primarily associated with the BBC, their public expressions of opinion on controversial issues or matters of current public policy have the potential to compromise their own and the BBC's impartiality or cause other reputational damage. This includes displaying emblems, joining protests or marches, supporting campaigns or signing petitions, writing open letters to the press, to politicians, or to any external organisation. Any such view placed in the public domain, may present an actual or perceived conflict of interest.
4.4.15 Taking a public position on an issue of current public policy, political or industrial controversy, or any other 'controversial subject' may be incompatible with some BBC roles. Advance discussion with line managers is essential in all genre areas.
4.4.16 Individuals must consult with the relevant senior editorial figure in their area who may also consult the Press Office on public expressions of opinion if they deal with the subject matter of their BBC content, relate to the BBC or broadcasting, or concern matters of current public policy, political or industrial controversy or any other 'controversial subject'.
(See Section 2 Impartiality: 2.1 and 2.4.12-2.4.15)
4.4.17 Presenters who only occasionally present programmes for the BBC should normally consult the relevant senior editorial figure over public expressions of opinion relevant to the subject matter of their programmes, if they are to be published around the time of transmission.
Additional Requirements in News and Current Affairs and Factual Journalism Output Dealing with Current Public Policy Issues
4.4.18 Individuals involved in the production or presentation of any output of this nature have additional restrictions and must not:
- state or reveal publicly how they vote or express support for any political party or candidate
- advocate any particular position or change regarding a matter of current public policy or party-political debate, political or industrial controversy, or any other 'controversial subject'
- speak or write publicly about the BBC without specific, prior approval from the relevant Head of Department.
(See Section 2 Impartiality: 2.4.12-2.4.15)
Rare exceptions, for example, when an individual is personally affected by a specific matter, must be declared as a potential conflict so that mitigating action can be considered.
Political Activities
4.4.19 Anyone is entitled to be a member of a political party or other organisation within the law. However, individuals in some roles need to consider whether public disclosure of such membership would risk compromising public confidence in their ability to fulfil some or all aspects of their job, or otherwise risk affecting perceptions of the BBC's impartiality.
4.4.20 Active involvement in a political party – or other public activity which demonstrates a political view – may give rise to a conflict of interest for those engaged by the BBC or who are publicly associated with the BBC.
Such activity must not compromise the BBC's impartiality or integrity or compromise public confidence in the BBC. Judgements about what is acceptable will reflect individual circumstances, including the type of activity and the nature of the individual's BBC role.
(See Section 2 Impartiality: 2.4.12-2.4.15)
(See guidance: Conflicts of Interest)
4.4.21 Political activity is likely to be incompatible with some BBC roles.
Mandatory Referral: Chief Adviser Politics must be consulted at the outset if there is any possibility of political activity being perceived as a risk to BBC impartiality.
4.4.22 Seeking nomination as a party candidate in a national or local election, or expressing an intention to stand as an independent candidate, is incompatible with some BBC roles that may deal with matters of current public policy, political or industrial controversy, or any other 'controversial subject'. It is likely to be incompatible with most roles in news and current affairs (see below). Before any external discussion regarding nomination, it is important that individuals discuss with their line manager the implications for their professional responsibilities and any potential risk to the BBC's impartiality if such an intention becomes public.
Mandatory Referral: Any individual who intends to seek nomination as a party candidate for election at national or local level, or intends declaring publicly their independent candidacy, must notify their line manager in advance, who should then consult the Chief Adviser Politics before the intention is made public.
(See Section 2 Impartiality: 2.4.14)
Additional Requirements in News and Current Affairs and Factual Journalism Output
4.4.23 Any political activities, such as campaigning or expressing views on social media with regard to issues of current public policy and other controversial subjects, are likely to be incompatible with most roles in news and current affairs and factual journalism.
Being an active member of a political party is incompatible with most roles in news and current affairs and factual journalism. Advice may be sought from the Chief Adviser Politics.
Charities and Campaign Work
People may support charities and charitable causes which reflect their interests and sometimes lived experiences. This may give rise to a number of issues that need careful consideration, depending on the nature of the content and the individual's role at the BBC.
4.4.24 Any work undertaken for, or in support of, a charity or charitable cause should not imply BBC endorsement for one charity or cause above others. There will be particular sensitivities if the charity's work relates to matters of public policy, political or industrial controversy, or any other 'controversial subject'. Individuals must ensure their impartiality is not compromised by associating themselves with a charity operating in the same area as the output on which they work.
4.4.25 Many organisations, including campaigning and lobby groups, charities, newspapers and specialist websites, maintain a public position on matters of public policy, political or industrial controversy, or any other 'controversial subject'. Before becoming actively involved with, or offering public support to, an organisation with a partial or campaigning stance on such matters, individuals engaged by the BBC should give the same consideration to the impartiality risks as is required for party political activity.
Mandatory Referral: Any proposal by individuals, including presenters of flagship programmes, to work for, or be publicly associated with, charities, campaigning groups or lobbying groups must be referred to the head of department, who must consult Editorial Policy.
Additional Requirements in News and Current Affairs and Factual Journalism Output
4.4.26 Presenters, reporters and editorial people in news, current affairs, factual and consumer output should not normally associate themselves with any campaigning body.
Mandatory Referral: News and current affairs presenters should not front campaigns for charities or campaigning bodies as this could compromise the BBC's reputation for impartiality. Any proposal that would not comply with this must be referred to Director Editorial Policy and Standards.
Writing and Other Broadcast Commitments in all Media
4.4.27 All individuals involved in editorial output and those who provide support for such output may wish to undertake external work, including creating podcasts, writing articles or books, or writing for publications on websites and other third-party platforms. Such activity should not risk compromising the impartiality or integrity of the BBC or its content or risk damaging the reputation of the BBC.
Any proposals to write about current affairs, or matters of current public policy, or political or industrial controversy or other 'controversial subjects' must be referred to a senior editorial figure. In the case of freelances, referral must be made if publication is likely to coincide with the time of broadcast and any associated marketing and publicity.
(See guidance: Conflicts of Interest)
Additional Requirements in News and Current Affairs and Factual Journalism Output
4.4.28 Individuals involved in the production or presentation of news and current affairs and factual journalism output, including freelances primarily known for their BBC role, must refer proposals to write columns or blog posts for external publications in any media to a senior editorial figure in the relevant division.
The articles, whether regular or one-off, must be read by a senior editorial figure within the BBC and the content must meet the requirements of the Editorial Guidelines.
Individuals cannot write a regular newspaper or magazine column dealing with current affairs or matters of public policy, political or industrial controversy, or any other 'controversial subjects'.
Permission from a senior editorial figure is required for those working in news and current affairs and factual journalism to publish books. The book should not compromise the integrity or impartiality of the BBC.
Public Speaking and Other Public Appearances
4.4.29 Public speaking commitments or other public appearances should not compromise the impartiality or integrity of the BBC or its content, or suggest that any part of the BBC endorses a third-party organisation, product, service or campaign.
Where presenters of BBC content undertake off-air public appearances, it may compromise their on-air role for the BBC. They should not allow the use of the BBC's name or brands in connection with advertising for a public appearance, unless this has been cleared in advance by the BBC. There should be no suggestion of a BBC connection or endorsement of the third-party event or organisation, unless it is editorially appropriate and has been approved by the relevant head of department.
Additional Requirements in News and Current Affairs and Factual Journalism Output
4.4.30 Individuals involved in the production or presentation of BBC news and current affairs and factual journalism output – including freelances known primarily for their BBC role – must remain impartial when speaking publicly or taking part in events, such as a public discussion or debate. They must not promote any political party, campaigning organisation or lobby group. Chairing conferences may create conflicts of interests. They should not chair conferences which are a promotional exercise for a commercial company that directly supports any political parties, or is not impartial on a matter of current public policy, political or industrial controversy or any other 'controversial subject'.
(See Section 2 Impartiality: 2.4.12-2.4.15)
Academic Roles
4.4.31 BBC presenters and editorial figures may undertake academic roles while continuing to work for the BBC; however, these roles should not compromise the impartiality or integrity of the BBC or its content or risk damaging the BBC's reputation.
Media Training
4.4.32 BBC presenters, senior editorial figures, commissioners and other output producers may speak at conferences or other events about matters pertaining to broadcasting, journalism or general production. However, their involvement should not compromise the impartiality or integrity of the BBC or its content or risk damaging the BBC's reputation.
Providing media training may give rise to a conflict of interest if the individuals or organisations being trained are given instruction on how to present themselves in the media.
Mandatory Referral: Individuals involved in the production or presentation of editorial content for the BBC must obtain permission from their line manager before agreeing to provide media training. Freelance presenters must disclose their training work where it may be a conflict of interest with their work for the BBC.
Individuals should not normally undertake to provide media training for those they are likely to be required to interview, or interview those they have already trained.
Additional Requirements in News and Current Affairs and Factual Journalism Output
4.4.33 Mandatory Referral: Individuals involved in the production or presentation of BBC news and current affairs and factual journalism output – including freelances known primarily for their BBC role – should not normally undertake external media training work, including for commercial companies, charities and campaign groups. Any proposal to carry out such work must be referred to their line manager in advance and referred to Director Editorial Policy and Standards.
Individuals should not normally undertake to provide media training for those they are likely to be required to interview, or interview those they have already trained.
There may be occasions where individuals can be involved in media training, for example, to assist in the training of journalists; this must be approved by line managers.
Personal Benefits
4.4.34 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. This can include intangible benefits such as 'quid pro quo' favours or exchanges of benefits. The requirements of the Editorial Guidelines are consistent with the relevant BBC Anti-Bribery Code of Conduct and BBC Studios policies.
Any offer of hospitality from outside bodies or companies must be considered carefully to ensure it does not constitute a conflict of interest or compromise the public perception of the BBC's impartiality or integrity or otherwise risk damaging its reputation.
Mandatory Referral: Individuals must not accept personal benefits, or benefits for their family or close personal relations, from organisations or people with whom they might have dealings on the BBC's behalf. Unacceptable personal benefits include goods, discounts, services, cash, loans, gratuities or entertainment, including tickets, outside the normal scope of business hospitality.
Any exception to this, where it could affect production of content for the BBC, must be referred to the relevant head of department, who should normally consult Editorial Policy, to establish whether accepting the offer constitutes a conflict of interest.
The acceptance of products, goods (including clothing) or services for free or at a significantly reduced cost, for use in BBC content without prior approval could risk bringing the BBC into disrepute.
(See Section 15 Independence from Commercial and Other External Interests: 15.4.13-15.4.15)
(See guidance: Props)
On-Air Presenters and Others with a Prominent On-air role: Promotional Activity, including Commercial Advertising and Endorsements
4.4.35 The BBC does not seek to place unnecessary or unreasonable restrictions on people working for it in any capacity, whether on-air presenters or others with a prominent on-air role or off-air high profile production role such as showrunners, writers, directors etc. In many cases such personnel are not exclusive to the BBC and may be associated with a number of media outlets. An individual may not earn the majority of their income from appearing on the BBC and there are benefits to both the individual and the BBC in having a broad public portfolio. However, promotional activity, which includes commercial advertising and endorsements, must not risk damaging the integrity of the BBC content they are associated with, or risk damaging the BBC's reputation generally. Proposals for such activity should be referred to the BBC at an early stage.
An individual's external promotional work must not suggest BBC endorsement, compromise the BBC's values, bring the BBC into disrepute, or give the public reason to doubt the impartiality or integrity of the individual who is associated with the BBC, or the BBC content with which they are associated.
Even where there is no conflict of interest with an individual's on-air role, there are some products, services or organisations which on-air talent should not promote as the association would risk damaging the BBC's reputation.
Mandatory Referral: On-air presenters and others with a prominent on-air role such as judges, hosts, team captains etc must not promote tobacco products or adult services. However, any proposal for them to promote other products or services that may risk damaging the BBC's reputation, such as gambling, alcohol or vaping products, must be referred to a senior editorial figure.
4.4.36 When presenters and others with a prominent on-air role, such as judges etc, are considering new promotional activities or when engaging new people in such roles, consideration should be given as to whether the promotional activities will have – or could be perceived to have – undue influence on the editorial agenda of the BBC content with which they are associated.
The promotional activities that can be undertaken will vary according to the different areas they work in. There are likely to be fewer restrictions on those on-air presenters and others with a prominent on-air role working in entertainment, sport or lifestyle output than there are for those working in news and current affairs and factual journalism output. This applies as long as their integrity and the integrity of the output they are associated with is not compromised.
There will be fewer restrictions on an individual seen as an independent outsider, or expert, who presents few programmes, strands or a one-off series, but is not considered to be primarily BBC on-air talent.
4.4.37 On-air presenters and others with a prominent on-air role such as judges, etc should not promote products, goods, services or clothing, including accessories, that they use on air. Those, in any genre, engaged for the BBC, must not accept clothing, accessories or other products free, or at considerably reduced cost, on the understanding that they will wear, reference or use them on air. Nor should they appear on air wearing clothes or using products, goods or services which they have agreed, or been contracted, to promote or in which they have any financial interest.
(See guidance: Conflicts of Interest)
Additional Requirements in Some Areas of Factual Output
4.4.38 On-air presenters and others with a prominent on-air role who appear regularly in factual output which considers matters of current public policy or political or industrial controversy are unlikely to be able to take part in any promotional activity for third parties.
On-air presenters and others with a prominent on-air role on consumer output that covers a wide range of topics must not undertake any promotional work for third parties as there is no product or service outside the remit of the output.
On-air presenters and others with a prominent on-air role on consumer output that covers a specific topic may only be permitted to undertake promotions for products, goods or services entirely unconnected with the subject matter of the output.
On-air presenters and others with a prominent on-air role whose regular on-air role involves giving advice on the purchase or use of branded products must not undertake any promotional work for products or retailers associated with the subject matter of the output.
On-air presenters and others with a prominent on-air role whose on-air role involves giving advice on how to solve problems should not promote products or services which aim to solve these specific problems.
4.4.39 Mandatory Referral: Where an individual used in front of the camera/microphone is engaged on a limited or occasional basis in factual output, any proposal to undertake promotional work must be referred in advance to the head of department who should consult Editorial Policy. The timing of external commitments and promotions in relation to their BBC content may be taken into consideration.
4.4.40 Mandatory Referral: The guidelines are not intended to prevent individuals with expertise having established and appropriate commercial relationships in their field. This may apply, for example, to artists, musicians, chefs, restaurateurs and garden designers. Where there is any proposal to undertake external promotional activity, the relevant division should ensure that appropriate editorial procedures are in place so that there is no conflict of interest with their BBC role. Editorial Policy must be consulted.
Additional Requirements in Children's Output
4.4.41 On-air presenters and others with a prominent on-air role on children's output must not promote products, goods or services aimed specifically at children which are directly connected to the subject matter of the content they present. There may be exceptions where they have an external expertise and existing external commercial relationships in this field, for example artists, chefs or musicians.
On-air presenters and others with a prominent on-air role on children's output must not promote products that are likely to be harmful to children (such as alcohol or solvents) or which are incompatible with their on-air role (such as gambling).
On-air presenters and others with a prominent on-air role and their agents must abide by current legislation limiting external commercial engagements for products where their involvement is likely to make such products appeal to children.
Additional Requirements in News, Current Affairs and Business Programmes
4.4.42 On-air presenters and others with a prominent on-air role on news, current affairs and business programmes are not permitted to take part in any promotional activity for third parties. Promotional activities in relation to BBC group[2] functions may be permitted.
References to BBC Content in Advertisements or Promotions and Actors and Artists Replicating their BBC Roles in External Output
4.4.43 Advertisements or promotions involving talent associated with the BBC should not imitate, suggest a reference or connection to or 'pass off' BBC content, for example, by replicating any editorial elements of a programme. This could include characters, logos, titles, channel names or music or graphics associated with the programme, or using or directly imitating sets or key venues, catchphrases or format points from the content or anything else related to the style of the content that could reasonably suggest an association.
On-air presenters and others with a prominent on-air role associated with BBC output should not appear in promotional work, including advertisements, in a way which mimics or replicates their BBC role.
Actors, artists and performers from the same BBC output should not normally appear together in the same advertisement or separately across a series of advertisements for the same product. There will also be considerations around the timeframe for such promotions.
In circumstances where a personality/talent owns the IP in the content, there will be considerations around the timeframe of such promotions and the nature of such promotions.
The advertisement or promotion should not bring the BBC into disrepute.
(See Section 16 External Relationships, Including Commercial Relationships, and Financing: 16.4.23)
(See guidance: Conflicts of Interest)
External Activities by Regular Contributors to Third-Party Output, including Social Media Influencers
4.4.44 Consideration needs to be given to promotional or external activities undertaken by contributors who appear in programmes regularly but who are not engaged as presenters or as part of the presenting team. The BBC would not normally wish to restrict the advertising, promotional or external activities of those outside contributors. However, the BBC should not use contributors where such outside promotional or external activities could reasonably give rise to doubts about their impartiality, integrity or independence or that of the content to which they are contributing.
Social media influencers who appear on the BBC as regular contributors or presenters, are likely to have external commercial commitments, which may change rapidly with little notice, because of the nature of their work. The principles outlined in this section apply and care should be taken to discuss the nature of their past, current and upcoming commercial activities with them to ensure there is no conflict with their BBC work.
(See guidance: Personal Use of Social Media)
Presenters of News and Current Affairs and Factual Journalism Output Appearing in Drama
4.4.45 Mandatory Referral: Presenters of factual journalism output may be asked to recreate their roles in fictional output. This may risk confusing audiences and compromise the credibility of their own output. Any such proposal must be referred to their head of department.
Current presenters of BBC news output should not appear as news presenters in a fictional bulletin if there is a reasonable possibility that this could confuse or mislead audiences. Any proposal to do so, for example in a dramatic, comic, unrealistic or fantasy situation, must be referred to their head of department.
(See guidance: Fictitious News Bulletins)
Talent or Agent-Owned Independent Production Companies
4.4.46 The involvement of on-air presenters and others with a prominent on-air role or their agents in the ownership or senior management of independent production companies making content for the BBC is an increasing business reality and can add creative value. Such arrangements must not cast doubt over the impartiality, integrity or editorial decision making relating to any BBC output and must be worked through carefully.
It is essential that the BBC is seen to be, and can demonstrate that it is, in overall editorial control of all aspects of the content and has put in place appropriate measures to maintain editorial control and to ensure there is no conflict of interest. BBC content must not be used as a vehicle to promote the external commercial or other interests of talent or their agents.
There are strong risks of a conflict of interest if talent and/or their production companies are commissioned to produce programmes about themselves. The same applies to agents and/or their production companies who pitch content about the talent they represent.
Mandatory Referral: There may be circumstances where it is not possible to produce content about a specific personality, or area where the personality has unique access or expertise, unless it is produced by an independent production company owned by, or as a co-production with, that talent or an associated agency. Any such proposal will require strong editorial justification and must be referred to the relevant divisional director and Editorial Policy. Director Editorial Policy and Standards must also be consulted.
- [2] BBC group consists of the BBC's Public Services, the BBC World Service and the BBC's commercial subsidiaries ↩