Principles of ethical funding of the Investigative Journalism Programme of the Gazeta Wyborcza Foundation

1. § Investigative Journalism Programme

  1. The Gazeta Wyborcza Foundation ( hereafter: the Foundation) created the Investigative Journalism Programme ( hereafter: the Programme), bearing in mind that journalism is crucial to fostering democracy in Poland and across Europe and that investigative journalism serves the public interest by increasing accountability and transparency in the functioning of society: public authorities, local governments, economic and non-governmental entities, as well as religious associations.
  2. The aim of the Programme is to support the development and promotion of quality investigative journalism as a response to the challenges posed by the increasing domination and internationalisation of political and business power and criminal structures, as well as to changing media models in the age of digitalisation entailing a weakening of the financial situation of traditional media.
  3. The objective of the Programme will be implemented by financing and co-financing the production of investigative materials concerning the activities of state and local authorities, public institutions and persons, economic and non-governmental entities or religious associations. These materials will be intended for distribution in the media in Poland and other European Union countries.

2. § Transparency and independence

  1. The Foundation has adopted these Ethical Funding Principles (hereafter referred to as the Principles) in order to guarantee transparency of Programme funding sources and, consequently, to avoid the risk of conflicts of interest and to ensure transparency in the relationship between funding sources and journalistic materials supported by the Programme.
  2. The principles are also intended to ensure the independence of the Foundation and the beneficiaries of the Programme from its funding bodies.

3. § Forms of financing

  1. Funding of the Programme within the meaning of the Principles means:
    1. making cash donations to the Foundation;
    2. making in-kind donations to the Foundation;
    3. providing services to the Foundation or directly to the beneficiaries of the Programme free of charge or under preferential conditions compared to the market;
    4. making available to the Foundation or directly to the beneficiaries of the Programme other resources, such as office premises, movable property, objects of intellectual property rights (e.g. computer programmes) or technical infrastructure, free of charge or at conditions preferential to market conditions;
    5. transferring of funds or goods in exchange for the provision of services by the Foundation or by third parties consisting of the communication of such a transfer.
  2. Making donations, as well as transferring funds in cash or in-kind in any other form, directly to beneficiaries of the Programme does not constitute financing within the meaning of the Principles, but is subject to disclosure in accordance with § 6 of the Principles.

4. § Acceptance of funding - general principles

  1. The Foundation shall operate only through its authorised representatives, including its officers and employees. The Foundation is not authorised to accept financing from third parties who raise funds for the Foundation without prior authorisation, with the exception of funds raised in public collections conducted by the Foundation.
  2. The Foundation may accept financing in the form of cash only in the form of payments to the Foundation's bank account, with the exception of funds collected as part of public collections conducted by the Foundation.
  3. Acceptance of funding in the form of the provision of in-kind resources, the provision of services or the making available of other resources shall always be subject to the prior conclusion of a written or documentary agreement.
  4. The Foundation does not accept funding if the funds or resources earmarked for this purpose come from:
    1. persons convicted of a criminal offence by a lawful order:
      1. against peace, humanity or a war crime;
      2. financing of terrorist offences;
      3. accepting a financial or personal benefit or the promise thereof in connection with the performance of a public function;
      4. granting or promising to grant a financial or personal advantage to a person exercising a public function in connection with the performance of that function;
      5. other than those listed above, including for a fiscal offence, to the extent that, in the Foundation's opinion, this may adversely affect the independence or credibility of the Programme;
    2. persons and entities to whom specific restrictive measures apply pursuant to Article 118, para. 1, pt. 1 of the anti-money laundering and counter-terrorist financing law;
    3. persons and entities subject to financial sanctions under regulations of the Council of the European Union;
    4. persons and entities subject to financial sanctions under UN Security Council resolutions;
    5. persons and entities designated as being subject to sanctions on lists maintained by the US Office of Foreign Assets Control;
    6. relatives of the persons or entities listed above or their related parties, insofar as, in the opinion of the Foundation, the persons or entities listed above are the actual source of the funds.
  5. The Foundation will not accept funding for the Programme from members of the Board, Council or the Committee reviewing applications for funding under the Programme.
  6. The Foundation will not accept Programme funding from individuals or entities whose ideology or past practices (such as discrimination based on race, ethnicity, gender or gender identity, sexual preference, nationality, age, disability or other embodiment or manifestation of fundamental human rights) are unlawful or unethical or threaten the reputation of the Foundation.
  7. The persons or entities financing the Programme shall have no influence on the selection of the themes or authors of the projects submitted for co-financing, the content of the press materials produced within the Programme, the selection of the members of the Committee assessing the applications for co-financing, or the amount of co-financing for individual projects. When accepting Programme funding, the Foundation may agree to indicate the general subject matter to be covered by projects submitted for funding from the funding provider.
  8. The Foundation may in any case, also in cases other than those indicated in § 4 points 4-6 of the Principles, refuse to accept funding without stating the reasons.
  9. Acceptance of funding amounting to PLN 50,000 or more, regardless of whether the funding is made as a single operation or as several related operations, requires the prior opinion of the Supervisory Board of the Foundation (hereinafter: the Supervisory Board).
  10. The Supervisory Board will assess the proposed funding in terms of its compliance with these Principles, other documents of the Foundation, generally applicable laws and the reasonableness and advisability of accepting the funding, taking into account the origin of the funds, as well as the activities of the person proposing to finance the Programme by funding other entities or initiatives whose aims or methods are contrary to the objectives of the Programme.
  11. The Supervisory Board may appoint working teams consisting of its members or third parties whose task is to analyse the justification and advisability of accepting funding, in particular, to verify the reliability of persons declaring their willingness to finance the Programme and the origin of the funds intended to finance it. The Board may also commission third parties to carry out the analyses indicated in the previous sentence or to analyse the compliance of the proposed funding with these Principles, other documents of the Foundation, or generally applicable laws.
  12. The decision to accept funding, the value of which is less than 50 000 PLN, is taken independently by the Management Board of the Foundation (hereinafter: the Management Board), which is obliged in each case to take into account the requirements specified in § 4 points 4-6 of the Principles.
  13. The Foundation may accept funding from an entity whose identity it will not be able to establish or verify, in an amount not exceeding 5,000 PLN, with the exception of funding raised through public collections or crowdfunding.
  14. In case the Foundation receives funding without its consent and against its will, or in breach of the Principles, the Foundation will immediately return the received funding, and if that is not possible, it will transfer it to the Helsinki Foundation for Human Rights. In the case of a justified suspicion that funds received as part of the financing originate from a criminal offence, or from persons and entities to which special restrictive measures apply pursuant to Article 118, para. 1 pt. 1 of the anti-money laundering and counter-terrorist financing law, the Foundation will take all actions required by law.
  15. The Foundation shall be entitled at any time to withhold acceptance of funding or to terminate the funding agreement in the event that it becomes aware, after the agreement has been concluded, of information indicating a possible breach of the Principles with respect to the funder or the origin of funds intended to finance the Programme.
  16. The Foundation shall be entitled to inform the public about the refusal to accept funding, unless the prohibition to disclose such information results from generally applicable laws or a decision of an authorised body.

5. § Acceptance of funding - special rules

  1. The Foundation will accept funding from government bodies, agencies or other entities owned or controlled by them, regardless of whether they are presented as independent, only if the following criteria are met:
    1. the funding entity does not present any risk of interference with the Programme for political or other reasons;
    2. the operating principles and practices of the funding entity are not in conflict with the objectives, values and principles of the Foundation;
    3. acceptance of funding shall in no way restrict the freedom of the Foundation to select projects under the Programme.
  2. The Foundation will accept funding from independent foundations, charities and similar non-governmental institutions only if the following criteria are met:
    1. the source of funds is verifiable, legal and transparent;
    2. the previous activities of the funding entity do not contradict the aims, values and principles of the Foundation;
    3. accepting funding will not unreasonably restrict future opportunities to obtain funding for the Programme from other sources.
  3. The Foundation will accept funding from commercial entities and persons conducting commercial activities, including foundations or other entities under the control of commercial entities and persons conducting commercial activities, only if the following criteria are met:
    1. the agreement between the Foundation and the funding provider clearly states that the funding will be provided free of charge;
    2. the form of acknowledgement or honouring of the funder will be specified in the agreement, indicating in detail the nature and extent of such acknowledgement or honouring, taking into account the rules of honouring adopted by the Foundation;
    3. the funding provider has not engaged in deceptive advertising or promotional practices;
    4. accepting the funding will not unreasonably restrict future opportunities to obtain funding for the Programme from other sources.
  4. The Foundation will accept funding from individuals whose identity will be known before funding is obtained only if the following criteria are met:
    1. the agreement between the Foundation and the funding provider clearly states that the funding will be provided free of charge;
    2. the form of acknowledgement or honouring of the funder will be specified in the agreement, indicating in detail the nature and extent of such acknowledgement or honouring, taking into account the rules of honouring adopted by the Foundation;
    3. the agreement will stipulate any specific privacy issues for the person providing the funding, in particular maintaining their anonymity or not disclosing the amount of funding;
    4. in case the person funding the Foundation wishes to remain anonymous:
      1. will verify that the reason for anonymity is reasonable in the circumstances and that such expectation does not raise any material concerns regarding non-compliance with generally applicable laws or these Principles;
      2. will consider with such a person a less restrictive form of concealment of identity, such as the disclosure of their initials, place of residence, nationality or profession;
    5. if a person providing financing acting through an intermediary is expecting to remain anonymous, the Foundation will verify that the intermediary has a good reputation in its field and meets any other standard of evaluation the Foundation deems appropriate given the circumstances of the financing.
  5. The Foundation will only accept funding from public fundraising if the following criteria are met:
    1. the public fundraising will be organised in accordance with generally applicable legislation;
    2. if the organiser of the collection is not the Foundation, the Foundation will ensure that the practices used in fundraising are consistent with ethical standards acceptable to the Foundation, including: that the methods of collection are acceptable; that donations made in the fundraising are made solely for charitable motives and not in exchange for prizes or other benefits; that only actual, reasonable and customary expenses are funded from funds raised in the fundraising; that all expenses incurred and all complaints received are collected in an accurate, complete and verifiable manner and that the Foundation has access to such records upon substantiated request.
  6. The Foundation will accept crowdfunding only if the following criteria are met:
    1. The reputation and operating methods of the crowdfunding platform are in line with market standards and the Principles;
    2. to the extent that the crowdfunding platform identifies donors, their identity complies with the requirements of the Principles;
      1. the platform conducts checks to ensure compliance with all generally applicable laws on money laundering, terrorist financing and similar measures.

6. § Transparency

  1. The Foundation will regularly publish the full list of its donors at the Foundation's or Programme's website or in other materials of a similar nature, unless there is an obligation of anonymity in the concluded agreement.[1] [2] [3]
  2. The Foundation may choose, for economic reasons, not to disclose the details of funding entities whose contributions amount to less than PLN 50,000, but will disclose the total number of such entities and the total value of such funding.
  3. The Foundation will disclose the total number of funding entities who have requested anonymity and the total amount raised from them as separate information.
  4. The relationship between the Foundation and the entity providing the funding may be made public after acceptance of the funding, including the conclusion of an agreement to that effect, and by such other means as the parties may agree.
  5. The Foundation will periodically publish on its website, no less than once a year, reports on the state of accounts of the Programme, which will contain clear, complete and accurate information on the amount and sources of funding for the Programme and the expenses incurred in connection with its implementation.

Approved by the Supervisory Board of the Foundation on __ ________ 2021.

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