Conflict Register

A conflict exists when someone working on an investigation, an editorial call or a legal review has an interest or a relationship that could reasonably make their independence doubtful. That can include:

The test is not just whether someone is actually biased. It is whether the situation gives real grounds to doubt their independent judgment.

Anyone doing substantive work — reporters, researchers, investigators, editors, legal reviewers — must declare a material conflict as soon as they know about it.

No one may quietly decide that their own conflict is too minor to matter when it could affect their work, or appear to.

Declaring it lets the organisation choose the right safeguard, if one is needed.

Every declared conflict is judged on things such as:

• the kind of relationship;
• its financial or personal importance;
• how recent it is;
• the person’s part in the work;
• whether they can influence publication;
• how serious the matter is; and
• whether a reasonable reader would see it as material.

The safeguard is matched to the size of the risk.

Anyone making substantive editorial decisions must declare material financial interests in a subject, or in a business closely tied to one, that could reasonably affect their judgment.

That covers significant investments, debts owed in either direction, contracts and other financial exposure.

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

This applies where one of our lawyers, investigators, consultants or other professionals has advised, represented, worked for or served the subject, or someone on the opposite side.

Professional duties such as privilege and confidentiality continue to apply whatever this policy says.

Confidential or privileged information learned in an earlier professional role is never used as investigative material just because that client later becomes a subject.

A close personal, family or significant professional relationship with a subject, complainant or important source may have to be declared. What follows depends on the facts.

Where it creates a serious risk that independence could reasonably be questioned, recusal is normally considered.

A reporter, investigator, editor or other decision-maker who has had a serious dispute with a subject must declare it.

We will not knowingly let our pages be used to pursue a staff member’s personal, commercial or legal fight.

In the same way, material from a complainant locked in a private dispute is tested on its own merits — never simply adopted as our view.

Someone can be removed from all or part of an investigation when a material conflict puts independent judgment at unacceptable risk. They may be kept away from:

The work then passes to colleagues the conflict does not touch.

Where full recusal is unnecessary or not practical, we can require an additional, independent review.

For example, research by someone who once had a link to a subject can be re-checked by another researcher, editor or lawyer with no similar tie.

A person with a material personal or financial interest in leaving a record unchanged should not be the only one ruling on a serious challenge to it.

Where it helps, correction requests go to people who can judge them independently.

What matters is getting it right — not defending what we published before.

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

Our internal procedures never override the conduct rules an individual lawyer is bound by.

If a lawyer cannot properly take part, someone else takes over.

Finding a conflict does not mean a record is automatically taken down. We ask instead:

• is the evidence still reliable?
• was the editorial process materially affected?
• does it need an independent review? and
• do readers need to be told, to understand the record properly?

If the reporting holds up on its own, disclosure or a procedural safeguard may be the right answer rather than removal.

If the conflict seriously damaged the work, corrections or other editorial steps may follow.

A person or company can be a Research Member and also the subject of, a source for, or an interested party in one of our matters.

Being a member protects no one from investigation, and earns no special treatment either.

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

Staff providing paid member services may not promise or decide a favourable editorial outcome in exchange for membership.

No donor, investor, sponsor, commercial partner or other funder controls our investigations because they support us financially.

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

No funder may tie their support to a record being withheld or softened.

Our people must not request or accept money, gifts, job offers, services, hospitality or any other benefit from a subject where it could influence — or look as if it influences — how a record is handled.

Legitimate fees for clearly defined services, such as an approved Research Membership, are kept apart from editorial decisions.

Sources can have conflicts of their own. A source might be a:

We factor those relationships into how reliable we judge them to be. Hostility to a subject doesn’t make evidence false — and a document isn’t taken at face value just because it supports an allegation.

That is when independent corroboration matters most.

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

The register never reveals privileged, confidential or unnecessary personal information. Jump to the register.

We can hold back or limit details where publishing them would:

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

Where we can, we describe a conflict in general terms instead of leaving it out altogether.

These labels describe how we handled a conflict. They are not findings about any subject.

If you believe an undeclared material conflict is affecting our reporting, send it to us for review. It helps to include:

• the Dubai Scammers record concerned;
• the person or relationship you believe creates the conflict;
• why you think so; and
• any supporting evidence you can reasonably share.

We may come back with questions before deciding whether a conflict exists or needs action.