Conflicts of interest or the appearance of a conflict of interest must be avoided at all costs to preserve the integrity of our reporting and maintain the public’s trust. Our journalists must avoid conflicts of interest, real or perceived, and disclose unavoidable conflicts.Â
Jersey Vindicator employees and board members should not offer or provide directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place to any potential sponsor, customer, or other business associate of The Jersey Vindicator. Nor should employees offer or provide, directly or indirectly, any material, equipment or services to any individual in a position to make or influence any business or governmental decision affecting the Vindicator.
Conversely, Jersey Vindicator employees and board members should not solicit or accept, directly or indirectly, any payment, loan, services, equipment or any other benefit or thing of value, or any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place from suppliers or customers, or from any company, individual or institution that furnishes or seeks to furnish news, information, material, equipment, supplies or services to The Jersey Vindicator, or from anyone else with an actual or prospective business relationship with The Jersey Vindicator. Thus, for instance, we accept no free trips. Beyond that, we neither seek nor accept preferential treatment that might be rendered because of the positions we hold.
Board of directors members and advisory board members will not do any work for The Jersey Vindicator for pay to avoid conflicts of interest. A board member also cannot seek employment or any contracts with the organization for a minimum of three years after stepping down from the board.Â
Jersey Vindicator employees may not serve as directors or officers of any company devoted to profit-making, with the following exceptions:
- Companies owned by an employee’s family, where the employee has obtained the written consent of the head of Vindicator;
- Otherwise as approved in writing by the head of Vindicator.
Many organizations, for a variety of reasons, participate in the partisan political process, at various levels of government. As a publisher, The Jersey Vindicator is different. The Jersey Vindicator is nonpartisan, and does not contribute, directly or indirectly, to political campaigns or to political parties or groups seeking to raise money for political campaigns or parties, and Vindicator does not and will not reimburse any employee for any political contribution made by an employee. All news employees and members of management with any responsibility for news should refrain from partisan political activity, including signing petitions, participating in marches or rallies, displaying lawn signs or making political contributions. Other political activities (including “issue oriented” activity) are permitted, but should not be inconsistent with this code.
On the other hand, it is not the intention of The Jersey Vindicator to dissuade employees from participating actively in civic, charitable, religious, public, social or residential organizations. Such activities are permitted, and even encouraged, to the extent that they:
- Do not detract from performance or effectiveness at work;
- Are, in the case of board memberships, disclosed to an employee’s direct supervisor;
- Do not, by their extensiveness, cause Vindicator to subsidize or appear to subsidize the activity; and
- Do not otherwise violate this code. In the event that a conflict arises or may arise between an outside organization with which an employee is affiliated and the interests of Vindicator, the employee should refrain from participating in the conflicting or potentially conflicting activity.
No Jersey Vindicator employee should permit his or her Vindicator affiliation to be noted in any outside organization’s materials or activities without the express written approval of the editor-in-chief or managing editor, or unless the employee serves as a representative of Vindicator or unless the affiliation is merely noted as part of a broader description of the employee’s identity.
The use of Jersey Vindicator property — i.e. forthcoming news — as a basis for any investment decision is strictly prohibited. No employee or contractor with knowledge of any such forthcoming material may, prior to publication, buy or sell securities or in any way encourage or assist any other person in buying or selling securities, directly or indirectly, based on that information.
All Jersey Vindicator employees and contractors are expected to conduct themselves at all times in a manner that leaves no grounds for belief, or even suspicion, that:
- The creation or dissemination, or non-dissemination, of any news or other information was influenced by a desire to affect the price of any security;
- An employee’s personal financial situation with respect to investments is such that it creates a temptation to violate these rules; or
- An employee is beholden to newsmakers, information providers or market participants, creating a temptation to violate these rules.
No news personnel assigned to report on a specific industry may buy or sell securities in any company engaged, in whole or significant part, in that industry, nor may any member of the immediate family of any such employee do so.
Code of conduct compliance
The Jersey Vindicator takes this code of conduct very seriously. All employees of The Jersey Vindicator are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment, and to attest in writing that they have done so; all Vindicator employees shall be required, at the time this code is first promulgated, to read it and so attest. In the case of all members of management, and all news personnel, such written attestations shall be required once each year.
The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal.
Vindicator maintains an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his or her supervisor, or is not satisfied with the supervisor’s response, the employee is encouraged to speak with the director of finance & operations or anyone in management whom they are comfortable in approaching. Supervisors and managers are required to report suspected violations of this code to the general manager. In serious cases, individuals should feel free to contact the general manager, the editor-in-chief, or the chairman of the board of directors directly. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Anyone filing a complaint concerning a violation or suspected violation of this code or other Vindicator policies must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
No employee or director who in good faith reports a violation of this code will suffer harassment, retaliation or adverse employment consequences. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including dismissal.
Finally, and to repeat probably the most important point in dealing with these questions: When in doubt, ask.