The Warren Group’s newspapers, Banker & Tradesman and The Commercial Record, are business-focused publications for professionals in the real estate, banking, lending and related industries. Our mission is to provide fair, accurate, impartial and balanced coverage of issues and topics of interest and concern to our readers, enabling them to understand and assess the competitive environment and markets in which they work; trends and strategies being employed for success; and industry news of value and importance to their businesses.
Table of Contents
I. Conflicts of Interest
A. Contacts with Advertisers and Sales Staff
B. Treatment of Advertisers, Public Relations Personnel, and Sources
C. Advertisement Adjacencies, Use of Trade Names in Editorial, Product Placements, and Advertising Design
D. Gifts to Editors and Writers
E. Travel, Entertainment, and Junkets
F. Outside Activities of Editors and Staff
II. Standards for Editorial Operations
A. Fact-Checking
B. Anonymous Sources
C. Freelancers
D. Research
E. Feedback Mechanisms
F. Illegally-obtained Information
G. Copyrighted Material and Originality
III. Graphics and Photography
A. Charts and Graphics
B. Photographs and Illustrations
C. Use of the Publication’s Logo
IV. Issues Relating to Advertising and Sponsorship
A. Single-Sponsored Issues
B. Special Advertising Sections or Supplements
V. Conferences, Rankings, Sponsored Contests, and Trade Shows
A. Editorial Duties
B. Keeping Rankings and Contests Transparent
C. Rankings or Contest Results
VI. Digital Publications
A. Identify Advertising Content
B. Identify Special Advertising Sections
C. Approve Hypertext Links
D. Disclosure Policies for Online Publications
E. Online Features of Publications
I. Conflicts of Interest
Our editorial staff makes all final editorial decisions. In all ways, editorial coverage must be based solely on reader needs in the view of the editors. All dealings with non-editorial personnel should be conducted with the clear understanding that no preferential treatment should be expected from the interaction and that the journalistic principles outlined below will be followed.
A. Contacts With Advertisers and Advertising Sales Staff
1. Relationship Between Editorial and Advertising Sales Staff. Our editors shall not be solely responsible for soliciting advertising, although they may:
- work closely with advertising sales staff,
- refer potential advertisers to advertising sales staff, and
- consult with advertising sales staff on story, content and special section ideas.
Our editors shall make clear, when engaging in such activities, that final decisions about editorial content rest with the editors, and final decisions about matters pertaining purely to advertising sales rest with the advertising sales staff.
2. Sales Calls. If editors accompany advertising sales staff on sales calls, the editors should state clearly their reason for attendance.
3. Story Leads. If editors accept story leads from an advertiser, the editors should explain to the advertiser that rigorous editorial evaluations go into determining whether the information will be used.
4. Advertising Negotiations. Our editors shall not be involved in negotiations where pure advertising considerations, such as advertising sales contracts or payment, are discussed.
5. Job titles. Sales staff and other non-editorial personnel shall not use job titles that give the appearance of an editorial function. If an individual carries the title of editor/publisher, that individual, when dealing with an advertiser, must make clear whether the individual is acting as editor or publisher, and must ensure that editorial, advertising, and corporate responsibilities are kept separate.
B. Treatment of Advertisers, Public Relations Personnel, and Sources
Favorable editorial coverage or preferential treatment in an article must never hinge on the prospect of advertising sales, financial gain or other factors not related to editorial integrity.
1. Article Previews. In general, non-editorial staff should not be permitted to preview unpublished articles or other editorial material. Exceptions to this rule include experts, editorial advisory board members, or other sources who will receive no benefit from the article. This rule still applies when a company or public relations person suggests an article. However, when a source or a company is referred to in an article, it may be acceptable for the editor or reporters to allow that the source review quotes or story sections to ensure accuracy or clarity. The Warren Group’s preferred method for this is to summarize the context of the quote and read back or e-mail only the direct quote to the source.
2. Negative Content. Advertisers may be informed in advance of any editorial material that may be viewed as critical of the advertiser, so that the advertiser may withdraw an advertisement from the issue.
3. Editorial Review. Our editors shall review, before publication, all advertising-supplied content for sponsored projects or articles, special-advertising sections or supplements, or other content that advertisers or sponsors may have provided to ensure that ethical guidelines are followed. Our editors have the right to reject copy that violates our editorial policies.
4. No Quid Pro Quo. There should be no trading of advertising for editorial content or editorial content for advertising.
5. Public Relations Personnel. The following guidelines state our preferred editorial procedure in dealing with public relations personnel during the preparation of material for publication:
a. If the contact involves arranging for an expert author to produce an article, at an editor’s request, the author should be identified as a guest contributor, with company affiliation and job title clearly listed. Listing a contributor’s e-mail or company Web address is acceptable; listing of phone numbers is discouraged. The article provided should meet all editorial requirements set by the editors and should be edited in the manner of staff-generated or freelance-contracted content.
b. Public relations personnel may be asked to help arrange contacts with key sources.
c. When an article or idea originates in a public relations department, our editors and reporters may seek more details from this and other sources.
d. When additional interviews are needed, public relations practitioners may help make appointments and advise our editors on appropriate personnel with whom to speak.
e. Our editors and reporters may seek background and illustrative information from public relations personnel to accompany articles, and our editors and reporters may also consult public relations personnel to obtain company clearance for story information, or to contact designated personnel to speak to the editors, when needed.
f. If the same person occupies the role of performing public relations and advertising duties, a clear distinction should be maintained between the two functions. It is advisable, however, for editorial staff to seek an alternative source in any case in which a conflict may result.
C. Advertisement Adjacencies, Use of Trade Names in Editorial, Product Placements and
Advertising Design
Generally, an advertisement should not appear next to related editorial content, to avoid the appearance of partiality or advertiser involvement. Exceptions include buyers’ guides, directories, annuals, or other ad-sponsored sections or supplements. Where appropriate, it is preferable to use generic names of products or services in editorial content. It is not acceptable for our editors, advertising staff, or other employees to receive paid or implied compensation to mention a brand or to place the picture of a product in editorial content. All advertising content should be clearly labeled as such.
D. Gifts to Editors and Writers
Generally, our editors and writers should not accept gifts from editorial information sources, advertisers or prospective advertisers, public relations personnel, or agents acting on their behalf. If gift-giving is an established custom, or is otherwise difficult to avoid completely, these guidelines should apply to acceptable gifts to editors and writers:
1. Modest, souvenir-type gifts commonly given out at press affairs or conferences, or distributed to large groups of editors or individual editors during traditional gift-giving seasons are acceptable.
2. Modest gifts sent to a large number of recipients are generally acceptable.
3. Money or lavish gifts for single recipients or a select few are not acceptable.
4. Avoid acceptance for personal use of “samples” or gifts of items, products, services, or other valued commodities that are or may be the subject of editorial mention.
5. We shall pay or split the cost for meals purchased by editors or writers in the course of discussing editorial matters with a source, a public relations representative or an advertiser.
E. Travel, Entertainment, and Junkets
In the case of transportation, lodging, entertainment and personal expenses incurred in connection with editorial coverage, the publication or the staff member is responsible for payment. There may be exceptions, however, including the following:
1. Junkets. In the case of group press affairs attended by our editors or staff and by editors from more than one publication, payment is optional, if the offer to pay expenses is extended by the information source or advertiser/vendor to all participants.
2. Speaking Engagements. In speaking engagements at an association, company affair or conference, accepting reimbursement of travel expenses is optional, if the engagement is a direct part of the editor or staffer’s job. Editors and staffers may not accept speaking fees at such engagements, since the speaking engagement is considered part of the employee’s work or job description.
3. Expenses. If a third party has paid travel and other expenses, our policy shall be to disclose the payments to the readers, if coverage results from the travel.
F. Outside Activities of Editors, Reporters and Newspaper Staff
Outside of the workplace, our employees’ activities may reflect on their professional lives. Editors, reporters and staff should be especially careful of conflicts of interest, or the appearance of conflicts in the following areas:
1. Outside Employment. During work hours, editors, reporters and other newspaper staff are expected to devote all their time and energies to the business of The Warren Group. Employees may not directly or indirectly engage in any outside employment, consulting or any other business activity which would conflict with their employment obligations at The Warren Group or would create an actual or potential conflict of interest. Such employment includes work for or engagement with any current, former or potential business competitor of The Warren Group.
While employed at The Warren Group, employees may not have a job with another organization or work as an independent contractor in any field (“outside employment,” “moonlighting” or “freelancing”) without disclosing the work and obtaining prior written consent from their direct manager. If an employee engages in any outside employment, that fact must be disclosed to his/her direct manager, and written consent must be obtained to continue that outside employment. This consent may be obtained via the Disclosure of/Consent for Outside Employment or Work Form, which can be found on the The Warren Group’s Intranet site.
The Warren Group’s objective is not to unreasonably restrict an employee’s ability to engage in outside employment as long as that employment does not interfere with and/or conflict with the employee’s work for or interests of The Warren Group in the judgment of The Warren Group. The final determination as to whether outside work represents and actual or potential conflict will rest solely within the discretion of The Warren Group.
Outside employment that may conflict with one’s duties with The Warren Group includes any outside employment that may constitute an actual or apparent conflict of interest, or which interferes with an employer’s work schedule at The Warren Group.
Any employee who obtains written consent from his/her direct manager to engage in outside employment must, at all times, meet all the requirements and responsibilities of the employee’s position with The Warren Group. Regardless of whether they hold outside employment, all employees of The Warren Group are held to the same performance standards and are subject to The Warren Group’s scheduling demands.
If an employee’s outside employment changes in any significant way, such as working additional hours, change in responsibilities or work for another organization or himself/herself, the employee has an affirmative responsibility to inform his/her direct manager of that change in circumstances by completing and submitting a revised Disclosure of/Consent For Outside Employment or Work Form. The original, signed Disclosure of/Consent for Outside Employment or Work Form should be given to the Human Resource Manager for insertion in the employee’s personnel file.
An employee’s failure to disclose and obtain written consent from an employee’s direct manager for any outside employment will be subject to discipline, up to and including termination from The Warren Group.
2. Investing. Our editors and staffers shall not invest in, or hold stock of, any company that they will cover or will be likely to cover. This constraint generally does not apply in the case of investments held in a mutual fund or 401(k) plan, or in similar plans that benefit the individual and other group members, and over which the individual does not control sales of individual stocks or other financial functions by which he or she might gain personally.
Our editors should never encourage investment decisions that reflect material in, or prepared for, our publications, or that involve a company that advertises in the publication.
3. Political, Community and Business Activities. Editors are free to participate in civic, political, business or religious activities that do not present a conflict with coverage or do not lead to a compromise of trust or respect for the publication.
II. Standards for Editorial Operations
The constant attention of our editors is required make sure that the entire editorial function, from preparing material for publication to offering a chance for readers and others to respond after the fact, is conducted fairly and in the readers’ best interests.
A. Fact-Checking.
We shall maintain a system that is independent of the original reporter and editor for the purpose of verifying the factual content in all of our published material. Content will be reviewed by at least two editors before publication.
B. Anonymous Sources
Whenever possible, we shall identify sources for readers. Exceptions should only be made in rare circumstances, such as to protect the source from the repercussions of speaking to the reporter. If a reporter must cite a source anonymously, the editor should be informed of the identity of the source and should use the most complete and accurate description of the source possible without compromising the source’s identity. If an employee knows that the source obtained information through illegal means, or that other potential legal issues exist with regard to a source or story, that employee shall make his or her concerns known to an editor prior to publication of the story, or as soon as the employee has reason to know of the potential illegal conduct. Editors shall report any such circumstances to the publisher and seek legal guidance.
C. Connection to Parent Company
When citing data from The Warren Group in news stories, those stories should clearly establish the connection between the newspaper and its parent company.
D. Freelancers
The same guidelines governing regular staff govern paid or unpaid contributing writers, editors, artists or other contributors. Our editors should respect the right of freelancers to work for other publications, although editors are entitled to discuss limitations – so that the same contributor does not have bylined work appearing in competing publications, for example.
E. Research
In the case of any research, rankings, awards, buyers’ guides, “best of” or “worst of” awards or similar editorial products, a neutral third party, such as a consulting firm, may be used to help avoid conflicts of interest. In any such editorial content, a clear and complete discussion of the methodology, including methodological and analytical limitations, should be published or cited in such a way as to allow the reader to make informed judgments about the value of the content.
F. Feedback Mechanisms
Our editors shall ensure that publications are accessible to readers, and shall arrange for appropriate feedback, which is to be treated responsibly if published. Editors should apply the following standards:
1. Contact Information. We should provide a range of ways for readers to offer feedback, including by mail, e-mail, and telephone. All of these avenues are to be disclosed in prominent sections of our print and digital publications. When possible, an e-mail address for reporters will appear following their stories. Each newspaper will print in its masthead, typically on Page 2, the following each week: Phone, fax, mailing address and Web address. The editor in chief or editor’s e-mail address shall appear each week on the editorial page.
2. Letters to the Editor. Space should be provided in our publications for letters. Editors should make every effort to verify their authenticity. Editors must also identify each letter’s author, business affiliation and/or hometown except when disclosing the author’s name may cause harm to the author.
3. Corrections. Requests for corrections, clarifications and retractions will be researched and evaluated by the editors. Corrections, clarifications and retractions should be printed in the next available issue, in a regular and consistent space that is easy for readers to locate - preferably in the front section of the publication. While it is best to place these corrections, clarifications and retractions in the same area of the publication in each issue, in the case of a major correction, our editors will determine whether it may be appropriate to place the correction in a place at least as prominent as the original material containing the error. In the interest of consistency and visibility, corrections, clarifications and retractions shall be placed at the bottom of Page 3 in Banker & Tradesman and The Commercial Record whenever possible.
4. Internal Complaints. Staff and other internal suggestions and complaints about our operations, ethics or quality should be taken to the editor in chief or editor of the publication. If the issue is not resolved at this stage, then the publisher should be informed.
F. Illegally-Obtained Information
No editor, staff member or other employee should be involved in any illegal activities in connection with obtaining information. In the event that an employee learns that a source has provided information that may have been obtained illegally, that employee shall inform an editor of the potential illegal conduct, and that information shall be reviewed at the highest editorial level, including the publisher, prior to publication, if published. Our editors shall consult with counsel when questions of reporter misconduct or illegality arise in connection with editorial material or with the operation of our print or digital publications.
1. In dealings with story sources and subjects, editors and reporters should clearly identify themselves from the beginning of any conversation, including making clear their job title and newspaper affiliation. Any investigative reporting activities that would deviate from this policy must be approved by editors, the publisher and legal counsel.
G. Copyrighted Material and Originality
It is the policy of The Warren Group’s newspapers to obtain permission to print or post all copyrighted material such as graphics and photographs. Permission obtained by e-mail from the granting authority is acceptable for this purpose. In all cases, we will credit or source the material appropriately as requested. In addition, it is expected that the work submitted by TWG reporters and photographers will be original. In cases where excerpts, quotes or other references to previously published outside reports are cited, TWG will note the source of the information.
III. Graphics and Photography
We shall prepare graphic materials with the same care and concern for accuracy, fairness, balance and attribution as the text component. The integration of the graphic and text components must be done responsibly to ensure readers’ trust.
A. Charts and Graphics
Informational graphics should include the source of the information, and should conform to the standards outlined in the above section entitled “Research.” This standard also applies to graphics obtained from third parties. Special care should be taken to ensure that all charts and graphs fairly and accurately represent the material presented in any accompanying article.
B. Photographs and Illustrations
We shall not modify photographic material in ways that could mislead the reader.
Whenever content of a photograph has been altered in a major way, the extent of the alteration and the technique should be clearly explained in a caption/cutline or credit line. All requested photo credits shall be published on first use of an image. Photo credits shall not be required for use of file photos on subsequent use.
C. Use of the Publication’s Logo
We shall not use our logo or allow it to be used without express written permission in promotional materials, unless the advertising is for a product connected with our publications, such as a conference or an authorized reprint of one of our stories. Our logo may be used in conjunction with buyers’ guides, directories, annuals, or with contests or competitions that have the editor’s approval and do not mislead readers or otherwise risk jeopardizing the integrity of the publication.
IV. Issues Relating to Advertising and Sponsorship
A. Single-Sponsored Issues
In the case of an advertiser sponsoring an entire issue or section, we shall fully disclose this relationship in a prominent part of that issue, e.g. the cover, table of contents or in a special introduction by the editor or publisher. Special care should be taken to avoid the appearance of editorial content being affected by the sponsorship. In a single-sponsored issue, our logo may be used, but the editorial content must be held to the same standards that apply for a non-single-sponsored issue.
B. Special Advertising Sections or Supplements
In general, all advertising should have a design different from editorial content, at least in typeface or headline style. Special ad sections and supplements should be clearly labeled with the word “advertising,” “advertisement,” “sponsored by,” or a similar designation. Our publication’s logo should never be used with a special advertising section or supplement in such a way that could give the appearance of editorial content being affected by sponsorship. Editors should review, revise and approve for publication any advertising section or supplement to ensure that editorial standards are followed.
V. Conferences, Rankings, Sponsored Contests and Trade Shows
Specialized coverage and the operation of publication-sponsored contests and rankings present many potential threats to our reputation, and require due care, as follows.
A. Editorial Duties
At conferences and trade shows, our reporters’ and editors’ primary duties are to collect news, learn industry trends, attend press conferences and program sessions, obtain articles and meet with writers, readers and others. When these obligations are met, our editors may use their discretion to meet with advertisers.
B. Keeping Rankings and Contests Transparent
In any rankings or contests that we publish, we shall fully explain the applicable judging criteria and rules, which should be unbiased, and we shall clearly identify any sponsors or judges.
C. Rankings or Contest Results
We shall not alter final rankings or contest results at the request of anyone in order to reflect an outcome different than the actual rankings or results. This policy should be made clear at the time of solicitation of entries or submissions of content for the rankings or contests.
VI. Digital Publications
Our editorial department should control all editorial content of any digital publication related to our print edition, including the related Web site, online edition, sponsored blogs and discussion forums, e-newsletters, digital magazines and the like. The same standards of accuracy, attribution and balance that we apply to our printed editorial material should also apply to our Internet or digital presence. In general, the same standards that we apply to advertising and sponsorship in our print edition also apply to any digital edition. Our home page and/or online edition and all pages of the digital publication should feature prominently our title and logo.
A. Identify Advertising Content
As with advertising in our printed editorial material, online advertising material and any online promotional “house ads” should be clearly identified on all pages and corresponding hyperlinks.
B. Identify Special Advertising Sections
As with special advertising sections in our printed editorial material, digital special advertising sections should also be clearly identified. An advertising notice should be placed prominently on each page displaying the content.
C. Approve Hypertext Links
Whether for editorial or advertising information, hypertext links should be placed at the discretion and approval of our editors. Advertising and sponsored links should be clearly distinguishable from editorial material. We shall not sell contextual links within editorial content, and our editors shall not link to a vendor’s Web site unless it is pertinent to the editorial content.
E. Disclosure Policies for Online Publications
1. Our Web site and/or online edition should clearly state our editorial policies, including advertising and sponsorship policies. These policy disclosures should include whether, how and why information is gathered from readers and other information-gathering means, including cookies, and they should provide users a way to opt out of any use he or she wishes to decline.
2. Terms of service and privacy policies should be prominently placed or referenced, easily accessible, and easy to understand.
3. We shall state on our newspaper Web sites whether user information is provided to third parties, including any related companies, subsidiaries and business partners, and we should allow readers to opt out of such information-sharing.
4. We shall provide complete editorial contact information, including a means by which readers can contact specific staff members with questions, corrections or other input. This information should be in a prominent, easily located position on the online publication, and should give readers multiple ways by which to contact us, including e-mail, telephone and by mail.
F. Online Features of Publications
Online features, such as blogs and forums, should be clearly labeled, easily found, and should have easily understood user guidelines. These guidelines should include general administrative rules applied to all users, and accurate descriptions of any applicable etiquette or privacy policies. Policy statements which concern moderation or control over user-provided content should clearly express all rules and terms of use.
