The Mint, a daily newspaper published from the Hindustan Times stable in New Delhi (owned by HT Media), has devised a comprehensive code of journalistic conduct and provides all its employees with guidelines for appropriate professional conduct. The code is available on the newspaper’s website. The newspaper claims that the code is intended not as a statement of new beliefs or a codification of new rules of conduct, but as a reaffirmation of enduring values and practices. As per the code of conduct, the newspaper does not pay newsmakers for interviews, nor does it pay them for taking their photographs or to film or record them. The code of conduct also enjoins upon its employees to prepare and place stories, graphics, and interactive features based solely on their editorial merits with an intention to treat companies that advertise with the newspaper in exactly the same manner as those that do not advertise. It asks its employees not to favour any company, or the subject of a story, nor to discriminate against any, for whatever reasons.

The newspaper also claims that editors and editorial imperatives dictate the design of their products and that the management makes allowance for the presentation of revenue-generating elements. However, the strong emphasis given to design elements ensures that the design always makes clear the distinction between editorial and commercial material. In the spirit of that rule, for example, the newspaper claims, it does not link, for any reason other than editorial purposes, from within the text of electronic versions of their stories to an advertiser’s website.

In order to ensure that these principles are honoured, the newspaper places emphasis on the fact that there is no contact (beyond social conversations) between the vast majority of the Mint’s editorial staffers and those who work in its business department. It authorises the Managing Editor or a designated surrogate to grant exceptions as necessary for the running of the business. The code of conduct further lays down that if any of its journalists or other employees ever feel any pressure from outside, or from the business departments of Mint itself, to compromise editorial material, including pressure to violate the code of conduct, they must immediately bring it to the notice of the Managing Editor and/or Deputy Managing Editor.

Here are a few excerpts from the code of conduct laid down by Mint for the professional conduct of its employees:

“Every judgment we make as journalists must be free of conflicts of interest – free even of the appearance of conflicts. Therefore, we must observe the following rules:

(1) Share ownership and trading: In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of Mint may engage in short selling of shares, including futures and options, such as a put option.

(a) Shares you own: You may not report, write, or edit a story about a company in which you or members of your immediate family own shares--nor about other companies in the same industry, unless it has been cleared in advance by the Managing Editor. For instance, if you own shares in Reliance, you may not report, write, or edit a story about the company or its key rivals. Nor may you mention such a company on a broadcast or cable show or Web video except in passing (as in reading a list of closing market prices). Immediate family means spouse or significant other and children 18 or younger.
You may, however, invest in diversified mutual funds, diversified exchange traded funds.

In any instance where a conflict seems likely, you might have to recuse yourself from participating in the story. Again, when in doubt, ask.

(b) Shares you plan to buy: If your job is such that you write about or edit stories on a wide variety of companies intermittently, do not invest in those companies.

You may, however, trade the shares of companies you don’t cover, in industries you don’t cover, provided you don’t act on any information prior to being published in Mint.

You may not engage in day trading or so-called active trading, or short selling. Nor may you accept “friends and family” shares from companies that are about to go public. Nor may you knowingly participate in unethical market-timing schemes that any mutual fund may engage in. The three-month rule does not apply to publicly available mutual funds.

Additionally, you may not trade in any share or financial instrument based on information gathered by anyone at Mint before a story is published. If an article on the information is not published by Mint but the information becomes public information the above restriction does not apply. Be aware that we may report suspected insider trading to the appropriate authorities and will cooperate fully in any subsequent legal actions. Remember, as well, that people who are caught engaging in insider trading often spend time in jail.

Employees are encouraged to be long-term investors in Mint stock.

(c) Special situations: There may be instances in which an editorial employee inherits stock from a non-spousal relative, or in which a newly hired employee or a person who is under contract to Mint arrives with stock holdings. In such cases, you have these options:

• You can divest your holdings.

• You can ask the Managing Editor to let you keep your holdings with the understanding that you must recuse yourself from covering companies (and their industries) in which you own securities.

Be aware, though, that even if you get such permission, recusing yourself extensively could limit your assignments and your ability to perform your job.

(2) Reporting share ownership: You must disclose in a confidential memo to the Managing Editor your ownership of shares in individual corporations and also such holdings of your spouse, significant other, and other members of your immediate family. Your shareholdings memo does not have to disclose the number of shares you own, just the company names.

You must submit this memo on your holdings to the Managing Editor every six months using a form that will be provided to you. New editorial employees must sign this code when they are hired -- and immediately thereafter submit the required share-disclosure statement.

(3) Reporting other conflicts: You must include with your financial disclosure memo a description of any other potential conflict of interest, including your other financial holdings plus any personal conflict that might arise from family connections or employment. If your spouse works at, for example, Reliance or The Economic Times, please disclose this information.

(4) Other conflicts: During the discussion of a potential assignment, you must also disclose other business activities that may conflict with your Mint work, or that may appear to. Such activities include but aren’t limited to: Holding a part-time job, working as a consultant, engaging in any form of public relations in any capacity, accepting speaking fees, ghost writing material for anyone other than an independent author, accepting compensation in any form for anything other than journalistic work, writing for publications that Mint considers to be competitors, and doing commercial photography or design work for the subject of a story or a broadcast segment you’ll be helping Mint prepare.”

Mint further lays down guidelines on the financial dealings with sources and subjects of stories; restrictions on accepting gifts, meals and entertainment and travel advisories for its journalists.

“…In situations where a company with whom Mint has an editorial partnership offers you favours, you must comply with the Mint Code of Business Ethics, which states in part: “No gift having more than nominal value and no loan (other than a normal bank loan) may be accepted from any person or firm having current or prospective dealings with the corporation.”

In relation to political and civic activities, Mint lays down the following guidelines.

“Many companies, for a variety of reasons, participate in the partisan political process, at various levels of government. As a publisher, Mint will have a different tradition. Mint does not contribute, directly or indirectly, to political campaigns or to political parties or groups seeking to raise money for political campaigns or parties. All news employees and members of senior management with any responsibility for news should refrain from partisan political activity judged newsworthy by their senior editor or in the case of senior management, the Managing Editor. Other political activities (including “issue oriented” activity) are permitted, but should not be inconsistent with this code.”

It should be noted that very few publications have codified ethical norms of conduct and behaviour of its staffers in the manner the Mint has. The Press Council of India would encourage all media organizations to not merely emulate such an example but, more importantly, also ensure that all staffers adhere to the ethical norms and principles laid down in letter and spirit.

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