Code of Ethics and Practices for Employees at WUWM 89.7 — Milwaukee's NPR

WUWM has a code of ethics that all staff members follow.

As employees of the Universities of Wisconsin System (UW System), all WUWM staff members must comply with policies on conflicts of interest and ethical standards. They are: https://www.wisconsin.edu/compliance/ethics/

As employees of WUWM, we adhere to a code of ethics and practices that are guided by our organization’s values, mission and vision.

As journalists, our listeners trust us to provide an honest portrayal of issues and events in all of our broadcasts. They need to know that our reporting is not influenced by outside interests, political influences or personal agendas.

And as development professionals, our listeners and donors trust us to behave in an ethical manner with full transparency regarding our fundraising practices.

This document is intended to outline how the University codes apply to all employees and our work at a public radio station. It draws liberally from the ethical guidelines adopted by the NPR Board of Directors as well as the work of the University of Wisconsin Board of Regents policies and the work of the “Editorial Integrity for Public Media” project which engaged hundreds of executives and senior staff of public broadcasting organizations, faculty from schools of journalism, and advisers in the areas of philanthropy, community engagement, and new media.

Adopted November 2013. Revised February 2025.

Common Sense Principle and Language

It is not possible for a document like this to address all possible situations that may occur. When an issue arises, employees should discuss the matter with their supervisor. The supervisor should seek guidance from the general manager as needed. The general manager may seek the guidance of others with expertise in journalist ethics. The decision of the general manager is eligible for review by the Dean of the College of Letters and Science at the University of Wisconsin Milwaukee. WUWM employees who do not comply with the Code or breach the firewall may be subject to disciplinary action up to and including termination.

Throughout this document, the words “content team” are used as a shortcut. This term is intended to include those individuals who gather, edit, deliver or manage informational programming on our air and on digital platforms.

THE PRINCIPLES OF INDEPENDENCE AND THE PUBLIC TRUST

Public media organizations contribute to a strong civil society and active community life, provide access to knowledge and culture, extend education, and offer varied viewpoints and sensibilities.

The freedom of public media professionals to make editorial decisions without undue influence is essential. It is rooted in America’s commitment to free speech and a free press.

Trust is equally fundamental. Public media organizations create and reinforce trust through rigorous, voluntary standards for the integrity of programming and services, fundraising, community interactions, and organizational governance.

These standards of integrity apply to all the content public media organizations produce and present, regardless of subject matter, including news, science, history, information, music, arts, and culture. These standards apply across all public media channels and platforms – broadcasting, online, social media, print, media devices, and in-person events.

Public media, individually and collectively:

Contribute to communities’ civic, educational, and cultural life by presenting a range of ideas and cultures and offering a robust forum for discussion and debate.
Commit to accuracy and integrity in the pursuit of facts about events, issues, and important matters that affect communities and people’s lives.
Pursue fairness and responsiveness in content and services, with particular attention to reflecting diversity of demography, culture, and beliefs.
Aim for transparency in news gathering, reporting, and other content creation and share the reasons for important editorial and programming choices.
Exercise care in seeking and accepting funds and setting boundaries between WUWM financial contributors and content creators, protecting the editorial process from the fact and appearance of undue influence.
Encourage understanding of fundraising operations and practices, acknowledge program sponsors, and disclose content-related terms of sponsor support.
Maintain respectful and accountable relationships with individual and organizational contributors.
Seek editorial partnerships and collaborations to enhance capacity, perspective, timeliness, and relevance and apply public media standards to these arrangements.
Be aware that the community may see you as a representative of the station, even in your private life.
Promote the common good, the public interest, and these commitments to integrity and trustworthiness in organizational governance, leadership, and management.

KEY PRINCIPLES GUIDING OUR JOURNALISM

ACCOUNTABILITY

We take full responsibility for our work, so we must always be ready and willing to answer for it. Just as careful attention to our sources makes a story stronger, careful listening to our public makes our journalism better. So, we welcome questions or criticisms from our stakeholders and to the best of our ability, we respond. Mistakes are inevitable. When we make them, we correct them forthrightly, reflect on what happened, and learn from them.

ACCURACY

Diligent verification is critical. We take great care to ensure that statements of fact in our journalism are both correct and in context. In our reporting, we rigorously challenge both the claims we encounter and the assumptions we bring. We devote our resources and our skills to presenting the fullest version of the truth we can deliver, placing the highest value on information we have gathered and verified ourselves.

FAIRNESS

To tell the truest story possible, it is essential that we treat those we interview and report on with scrupulous fairness, guided by a spirit of professionalism. We diligently pursue responses from those who are the subject of criticism, unfavorable allegations or other negative assertions in our stories. What we broadcast and put online may be edited for time and clarity. We air political interviews ‘as is.’ Whenever we quote, edit or otherwise interpret what people tell us, we aim to be faithful to their meaning, so our stories ring true to those we interview. We strive to consider multiple perspectives, seeking to deliver both nuance and clarity. Our goal is to seek the truth and inform the public.

GENERATIVE AI

One of the important ways that WUWM differentiates itself is that we produce, report and tell trusted, stories about our community on a human scale, made by humans. The recent advances with Generative Artificial Intelligence offer a myriad of tools and possibilities to help us be more efficient at our jobs – and possibly better journalists and content producers – but it can’t replicate the core function of human storytelling: listening, witnessing, contextual processing, fact-checking, and reporting.

There are a growing number of AI-based and AI-assisted tools that are useful and can be used to help our work be more efficient and inclusive. For example, an AI-assisted service for text transcription can make our journalists and storytellers more efficient in their work and AI-assisted captioning can make our content more accessible to people who are Deaf or hard of hearing.

We view AI as a tool in the service of our work and to advance our mission. Our use of AI is also guided by the ethical and journalistic principles outlined in this document.

However, it is vitally important that our community can trust that our voices, storytelling, and reporting are made by humans, and as such, we consider the undisclosed use of AI and generative AI in our reporting and text generation for stories to be plagiarism and must be avoided.

If staff choose to use a large language model (LLM) like ChatGPT or any of its competitors, use caution since information entered into the LLMs can become part of its knowledge set. Never upload sensitive information as no LLM service can protect the full privacy of the data you submit.

All uses of AI – inclusive of our content and administrative teams – will be clearly disclosed on our website and in very specific, approved circumstances, in our bylines.

As this is a quickly developing technology, we direct WUWM employees to the guidance provided by NPR on Generative AI and in UWM Guidelines at https://guides.library.uwm.edu/ai or https://uwm.edu/marcomm/policies/guidelines-on-use-of-chatgpt-and-other-predictive-language-models/.

The use of AI is an ongoing conversation at WUWM and this guidance may change.

HONESTY

In the course of our work, we are genuine and candid. We attribute information we receive from others, making it perfectly clear to our audience what information comes from which source. We edit and present information honestly, without deception, and we identify ourselves as WUWM journalists when we report.

INCLUSION

To create a sense of belonging, we center the community in our work. We strive to reflect the full scope of our diverse listening region both in our staff and in our programming. As a public service, we make our programming accessible to all.

PLAGIARISM

Plagiarism is an unforgivable offense. WUWM journalists do not take other people’s work and present it as our own. This would result in HR or code of conduct action with UWM.

The Associated Press is a service that WUWM pays for and as a part of the contract, we do not have to attribute the work to them, unless it is exclusive to the AP. We use the AP byline if we use a whole story on our website. It is not appropriate to represent an AP story as your own.

RESPECT

Everyone affected by our journalism deserves to be treated with decency and compassion. We are civil in our actions and words, avoiding arrogance and hubris. We listen to others. When we ask tough questions, we do so to seek answers -- not confrontations. We are sensitive to differences in attitudes and culture. We minimize undue harm and take special care with those who are vulnerable or suffering. And with all subjects of our coverage, we are mindful of their privacy as we fulfill our journalistic obligations.

TRANSPARENCY

To inspire confidence in our journalism, we welcome the evaluation of our work. We share as much as we practically can about how we discover and verify the facts we present. We strive to make our decision-making process clear to the public, and we disclose any relationships, whether with partners or funders, that might appear to influence our coverage.

KEY PRINCIPLES GUIDING OUR CONTENT TEAM

The content team is defined as anyone working as a host, journalist, reporter, producer, editor for anything that is distributed over the air on our broadcast signal, our website, or our social channels. It also includes digital teams and the VP of content. It includes everyone that creates anything editorial for the organization. This includes full- and part-time employees and shall include freelancers during the time they are working on WUWM projects.

The WUWM content team enjoys the right to robust personal lives, yet we accept some unique professional obligations and limitations.

CONTENT CONFLICT OF INTEREST

We are vigilant in disclosing to our supervisors any circumstances where our loyalties may be divided - extending to the interests of spouses and other family members - and when necessary, we recuse ourselves from related coverage. Under no circumstances do we skew our reports for personal gain, to help WUWM financially or to please those who fund us. Decisions about what we cover and how we do our work are made by our journalists, not by those who provide WUWM with financial support.

WUWM follows NPR on their standards and practices regarding outside activities that involve personal values. From the NPR ethics handbook:

"NPR editorial staff may express support for democratic, civic values that are core to NPR's work, such as, but not limited to: the freedom and dignity of human beings, the rights of a free and independent press, the right to thrive in society without facing discrimination on the basis of race, ethnicity, gender, sexual identity, disability, or religion.

We recognize that the line between standing up for human rights and being "political" is a fine one that looks different from different perspectives. A march for racial equality may be non-political in principle, for instance, but that may not hold true if the march is for a specific piece of legislation or where organizers or speakers include politicians aligned only with one party. The fact that others may attempt to politicize social issues, or the way people live their lives, does not mean that journalists are engaging in political activity. Decisions on participation will have to be case by case as a result."

Furthermore, in most cases the content team does not engage in public relations work, paid or unpaid. The case-by-case decisions will be made by the employee’s supervisor. Examples include (but are not limited to):

If a content team member is involved with an organization that they want to cover or pitches you a story, the appropriate action is to fully disclose your relationship to your supervisor for discussion. We will be transparent when reporting on organizations we are involved with.
If we want to do outside freelance work, we must get written permission from our supervisor. Freelance work includes anything paid or unpaid in the media locally and nationally.
Supervisors will approve any speaking engagement with organizations that might have a relationship to a subject that WUWM may cover.
From time to time, we may be asked to appear on TV or other media. We get permission from our supervisor so that there are no conflicts with our role at WUWM. During such appearances, we do not express views that would not air in our role as journalists on WUWM programs.
If the employee wants to appeal the supervisor’s decision, the question will be moved to WUWM’s GM.
Exceptions may be made for certain volunteer nonprofit, nonpartisan activities, such as participating in the work of a church or synagogue or charitable organization, so long as this would not conflict with the interests of WUWM in reporting on activities related to that charity.

KEY PRINCIPLES ESTABLISHING OUR JOURNALISTIC FIREWALL

A large and diverse group of funders supports our work, including many individuals, businesses, governmental entities, and foundations. Most of the funding we receive supports overall operations rather than specific programs or series. The diversity of sources, the number of contributors, and the unrestricted character of funds all reinforce the independence and integrity of our editorial process.

We give careful attention to contributions and grants that support specific programs, projects, and activities. We seek to avoid inappropriate influence.
We reserve the right to refuse any donation for any reason, including, but not limited to, perceived conflicts of interest, potential audience misconception regarding a funder’s role or influence, and perceived impact on our reputation, integrity, or fundraising ability.
We do not accept funding of ongoing news and information programming from political parties and candidates for public office.
We don’t accept funding that would obligate us to provide coverage of a topic that we would not have covered with general funds or that requires more extensive coverage than the topic’s value or importance warrants.
As journalists who deal with a wide range of community issues, it is inevitable that we will talk with experts and officials who work at organizations that fund us. We don’t allow funders to influence our coverage. The content team will not work directly with grant making organizations. The WUWM editorial team decides which stories and interviews we cover. The editorial team reserves the right to decline any pitch.
The team gets dozens of pitches a day and will not respond to unsolicited pitches, via any method, unless we are considering a story.
As public broadcasters and as recipients of charitable giving for much of our income, we must observe ethical guidelines related to fundraising.
WUWM maintains absolute editorial independence. While good program ideas or other good content may come from any source, under no circumstances will we allow undue or inappropriate influence on our content from funders. Examples of undue or inappropriate influence include direct requests to cover or avoid specific topics, attempts to influence the selection or framing of stories, and pressure to present a particular viewpoint.
We place a strong "firewall" between fundraising and content to ensure it is free from donor influence. WUWM will not accept a gift or corporate sponsorship with the expectation that the funding provided would give a donor or underwriter influence over content decisions or other station activities. This practice, whether intended to encourage or inhibit our work on any topic, would undermine our work as public media providers. WUWM accepts funding for general operations and funding for specific projects; we do not accept funding with "strings attached" related to the creation or subversion of content or other editorial functions.
WUWM coverage decisions will not be influenced by our relationship with the university or sponsors/donors.
The General Manager will designate individuals who will serve as contacts with funders for grant-making purposes or other communications.

KEY PRINCIPLES GUIDING ALL STAFF

We respect the active personal lives of public media employees and their many interests, activities, and relationships. We are mindful, though, that employees’ activities beyond their public media work can affect our reputation and public trust.

All public media employees are asked to:

Be alert and sensitive to conflicts of interest between personal interests (including family members) and their professional public media responsibility.
Be aware of the distinction between communications that are part of professional public media responsibilities and all other communications.

USE OF SOCIAL MEDIA

Social media sites are being created on a regular basis. But, activities that we intend to be private may impact the image of WUWM as viewed by members of the public. Anyone who has access to the internet may be able to access communications. All employees are free to express their personal views in a private setting but need to be careful as the definition of “private’” is evolving. As an organization, we refer to the current NPR social media policy as formal guidance for WUWM employees. There is no expectation that staff will be on any or all social media networks. If you are, we may ask but not expect you to post WUWM content.

CONFLICT OF INTEREST AND OUTSIDE ACTIVITIES REPORTING

WUWM defines conflict of interest and outside activities through the policy and conduct guidelines laid out by University of Wisconsin System, our employer and station license holder. Reporting and other UWM guidelines can also be found on their website.

All staff are required to adhere to these policies. Employees will find all reporting responsibilities and requirements, based on your staff position (academic or university) on these sites. All outside activities must be reported annually on the UW-Milwaukee outside activities report to be in good standing (meaning you are eligible for standard evaluations and UW System approved raises).

Employees may engage in outside activities related to the employee’s field of interest unless the activities conflict with the employee’s public responsibilities to the University of Wisconsin System and WUWM. When it appears that a material conflict may arise between the personal interests of a staff member and his or her public responsibilities, the staff member shall immediately notify their supervisor by submitting a written statement describing the nature of the possible conflict.

POLITICAL ACTIVITY

As employees of a public media organization, we have a special responsibility to maintain the trust of our audiences. As the public is becoming increasingly polarized, it is essential that the public can rely on us to be impartial, unbiased, and independent in our work.

Because of this, employees at WUWM may not engage in political activity in any capacity. This includes, but is not limited to, running for public office, campaigning for candidates, distributing political materials, displaying political endorsements, stickers, cartoons, or posters in office workspaces, making financial contributions, speaking at public meetings, or using organizational resources – such as email, social media, or office space – for political purposes. The organization remains nonpartisan, and employees are expected to uphold this standard in both their professional conduct and public representation. This prohibition does not extend to the family members of WUWM employees. However, as WUWM employees, we will make reasonable attempts to distance ourselves from this activity.

PERSONAL GAIN ASSOCIATED WITH WUWM EMPLOYMENT

No member of the academic or university staff may, in a manner contrary to the interests of the University of Wisconsin system, use or attempt to use his or her public position or state property, including property leased by the state, to gain or attempt to gain anything of substantial value for the private benefit of the staff member, their immediate family or any organization with which the staff member is associated. No employee may solicit or accept from any person or organization anything of value pursuant to an express or implied understanding that their conduct of university business would be influenced thereby. No employee may intentionally use or disclose confidential university information in any way that could result in the receipt of anything of value for themself or immediate family or for any other person or organization with which the staff member is associated. Nominal gifts (such as coffee mugs, T-shirts and books) may be accepted by an employee if it does not impact any action or decision by the employee.

UNIVERSITY PROPERTY AND ACCEPTABLE USE OF INFORMATION TECHNOLOGY RESOURCES

WUWM is a department within a public institution, any email or other communication sent on a university computer may become public if there is a request for public records. University resources such as office supplies, cell phones, meeting rooms, and work time should be used only for university purposes. Phone and email may be used for minimal personal use consistent with UWM policies. Never use UWM resources, including email and telephone, for outside work.

PAYOLA AND PLUGOLA

According to the Federal Communications Commission, any broadcast station employee who has accepted or agreed to accept payment for the airing of program material, and the person making or promising to make the payment, must disclose this information to the station prior to the airing of the program. Similarly, the FCC strictly prohibits ‘plugola’ or the illicit practice of endorsing a product or service on radio or television for personal gain. Violators may be subject to loss of employment, substantial fines or imprisonment.

NEPOTISM AND EMPLOYMENT DECISIONS

No employee may participate, formally or informally, in the decision to hire, retain, promote or determine the salary of a member of their immediate family. Disclose that relationship to your supervisor so that actions can be taken to minimize or remove any potential conflict of interest arising from that relationship, particularly if you are on a search and screen committee.

It is possible to remain on the committee and not be involved in the discussion of one or more applicants. The search committee chair and supervisor will decide how to proceed. The final decisions on these matters may be addressed by the GM if needed.

Employees may reach out to their networks and professional colleagues from other organizations to get the best group of applicants or contractors for any work at WUWM, but that relationship will not influence hiring or other human resources or purchasing processes.

OWNERSHIP OF WORK PRODUCT

As employees of the University of Wisconsin System, all work products are owned by the Board of Regents.

KEY PRINCIPLES GUIDING OUR FUNDRAISING ACTIVITIES

We aim for respectful relationships with our donors and a clear understanding among donors and others about our fundraising operations. We acknowledge the sponsors of our programming and disclose the terms on which we obtain such support.

In this document business sponsors and underwriters will be called “business sponsor” and individual donors and supporting members as well as foundations will be called “donors”.

Our public service depends on donations of all sizes from many different sources. We maintain the trust and confidence of these donors and our communities by making clear the purposes and uses for which we seek their support, making every effort to understand a donor’s intent prior to accepting the donation and, after accepting a gift, working to carry out the donor’s wishes. We then make every effort to report back to the donor on the impact of their gift, be it on air or individual conversations with donors.

We inform donors about how donor records will be used. We protect personal and confidential information that we obtain during fundraising activities or through our ongoing relationships with these donors.
WUWM participates in the required UWM credit card Payment Card Compliance (PCI) activities annually.
We do not exchange or rent our donor lists to other organizations.
We communicate directly and explicitly with donors about our editorial standards that bring rigor and integrity to our work, the legal requirements that surround our donor relationships, and the boundaries between funders and our editorial process. Within that framework, we keep donors informed about operations, welcome their suggestions and feedback, and value their role as advocates in the community.
Sponsorship of WUWM or membership on our WUWM Advisory Board does not include any influence over our editorial coverage.
There are times when members of our editorial teams may be asked to meet donors or sponsors. Our content teams will be expected to ask for money in general ways, including but not limited to, on-air membership campaigns. The reporters, producers, editors, content and digital staff will never be expected to ask an individual donor or sponsor for money.

FUNDER ACKNOWLEDGEMENT

We always disclose, on air or online as appropriate, the funders of specific programs, areas of coverage, or other activities. We acknowledge any person or organization that gives us money or other valuable consideration to broadcast specific content, as follows:

We acknowledge donors that sponsor the broadcast of a program with broadcast announcements associated with the program. We also acknowledge with broadcast announcements (providing permission is given) donors that have provided substantial general support. Our underwriting policy can be found here.
We acknowledge donors that support the production of specific programs in on-air announcements. We keep a list of these donors in the FCC public file available at WUWM.com. It is updated quarterly.
We do not accept anonymous gifts for the production of specific programs.
We publish a list of donors that have contributed funds for our general support, where we have received permission to do so.
We report the overall costs of fundraising, including personnel, consultants, special events, and related support costs. This reporting is part of our overall disclosure of revenue and expenses in our public file as part of our Annual Financial Report to the Corporation for Public Broadcasting.

GIFT ACCEPTANCE POLICY

WUWM retains the right to decline gifts for a variety of reasons. We are particularly sensitive to any gift that might create the appearance of influencing a program decision or create the impression of endorsement with an individual or organization that could cause harm to the reputation of WUWM or the University of Wisconsin System.