Conflict Register

A conflict can arise when anyone working on an investigation, an editorial decision or a legal review has an interest or relationship that could reasonably call their independence into question. Examples include:

The question is not only whether bias actually exists, but whether the situation creates a real risk that independent judgment could reasonably be doubted.

Journalists, researchers, investigators, editors, legal reviewers and anyone else doing substantive work must disclose a known material conflict as soon as they become aware of it.

Nobody gets to decide privately that their own conflict is too small to matter if it could reasonably affect — or look like it affects — their work.

Disclosure lets the organisation decide which safeguards, if any, are needed.

Each disclosed conflict is weighed against factors such as:

• what the relationship is;
• how much it matters financially or personally;
• how recent it is;
• the person’s role in the investigation;
• whether they can influence publication;
• how serious the matter being reported is; and
• whether a reasonable reader would think it material.

The response is proportionate to the risk.

Someone may be taken off all or part of an investigation when a material conflict creates an unacceptable risk to independent judgment. They may be excluded from:

Where appropriate, the work is handed to colleagues the conflict does not affect.

Where full recusal is unnecessary or impractical, we may require an extra, independent review.

For example, work by a researcher who once had a connection with a subject can be re-checked by another researcher, editor or lawyer with no comparable tie.

People making substantive editorial decisions must disclose material financial interests in a subject, or in a closely connected business, where those interests could reasonably affect their judgment.

That includes significant investments, money owed to or by the subject, contractual interests and other financial exposure.

Where the interest is material, recusal or another safeguard is normally considered.

This covers cases where one of our lawyers, investigators, consultants or other professionals has advised, represented, worked for or provided services to the subject, or to a party on the other side.

Professional duties such as privilege and confidentiality apply regardless of this policy.

We will not use confidential or privileged information obtained through an earlier professional relationship as investigative material just because that person later becomes a subject.

A person or business can be a Research Member and, at the same time, a subject of, source for or interested party in one of our matters.

Membership does not shield anyone from investigation — and it earns no preferential treatment either.

Where membership creates a material conflict in an investigation, it is disclosed internally and managed.

Staff who provide paid member services may not promise or decide a favourable editorial outcome in return for membership.

No donor, investor, sponsor, commercial partner or other funder gains control over our investigations because they give us money.

If we have a material financial relationship with someone who becomes a subject, that relationship is assessed as a possible conflict. Safeguards can include:

No funder may make their support conditional on a record being hidden or treated favourably.

Sources have conflicts too. A source might be a:

We take those relationships into account when judging reliability. Hostility towards a subject does not make evidence false; equally, a document is not accepted at face value just because it supports an allegation.

In these cases independent corroboration becomes especially important.

Our people must not ask for or accept money, gifts, job offers, services, hospitality or other benefits from a subject where doing so could reasonably influence — or appear to influence — how a record is handled.

Legitimate administrative payments for clearly defined services, such as an approved Research Membership, are kept separate from editorial decisions.

A close personal, family or important professional relationship with a subject, complainant or key source may need to be disclosed. What happens next depends on the circumstances.

Where the relationship creates a serious risk that independent judgment could reasonably be questioned, recusal is normally considered.

If a journalist, investigator, editor or other decision-maker has had a significant dispute with a subject, it must be disclosed.

We will not knowingly use our platform to advance a staff member’s personal, business or legal fight.

Likewise, information from a complainant caught up in a private dispute is evaluated independently, not adopted as our own conclusion.

Someone with a material personal or financial interest in keeping a publication as it is should not be the only person deciding a serious challenge to it.

Where appropriate, correction requests are reviewed by people who can assess them independently.

The goal is accuracy, not defending earlier work.

Lawyers reviewing material before or after publication must consider their own professional duties, including conflicts from current or former clients.

Nothing in our internal procedures overrides the conduct rules that bind an individual lawyer.

If a lawyer cannot properly take part, the matter is reassigned.

Where it is appropriate and lawful, we keep a public register of material organisational conflicts. Each entry can show:

For example:

The register never discloses privileged, confidential or needlessly personal information. Go to the register.

We may hold back or limit information where publishing it would:

• breach legal privilege;
• break a confidence;
• expose protected personal information;
• identify a confidential source;
• harm an investigation;
• create an unjustified safety risk;
• breach professional duties; or
• otherwise be unlawful.

Where possible, a conflict is described in general terms rather than left out entirely.

These labels describe how the conflict was handled. They are not findings about any subject.

If you think an undisclosed material conflict may be affecting our reporting, you can send it to us for review. Please tell us:

• which USA Scammers record is affected;
• the person or relationship you think creates the conflict;
• why you think so; and
• any supporting evidence you can reasonably provide.

We may ask for more information before deciding whether a conflict exists or needs action.

A conflict does not automatically mean a record comes down. Instead we ask:

• is the evidence still reliable?
• was the editorial process materially affected?
• is an independent review needed? and
• do readers need to be told to understand the circumstances?

If the reporting still stands up independently, the right response may be disclosure or a procedural safeguard rather than removal.

If the conflict seriously undermined the work, further correction or editorial action may follow.