Ethics & Conflict of Interest Policy

Purpose

The Public Ledger’s credibility depends on editorial independence. This policy ensures that conflicts of interest are identified, disclosed, and managed before they compromise the integrity of our reporting.

What Constitutes a Conflict of Interest

A conflict of interest exists when the editor, any contributor, or their immediate family members have a financial, political, or personal relationship with a subject of an investigation that could reasonably be perceived as influencing editorial decisions.

Examples include:

• Political: The editor or a contributor holds or seeks public office in a jurisdiction covered by an investigation
• Financial: The editor or a contributor holds a financial interest in an entity that is a subject of an investigation
• Personal: The editor or a contributor has a close personal relationship (family, business partner, employer) with an individual named in an investigation
• Professional: A contributor’s current or former employer is a subject of an investigation

Disclosure Requirements

All conflicts of interest must be disclosed prominently at the top of the affected article, before the body text begins – not in a footnote, sidebar, or end-of-article note.

Disclosure format:

Disclosure: [Name] is [nature of conflict]. This investigation is based solely on public records; all methodology is documented at /methodology/.

If a conflict cannot be adequately addressed through disclosure alone, the investigation must be referred or paused (see Recusal Procedure below).

Recusal Procedure

When a conflict of interest is identified, the editor will take one of the following actions:

1. Disclose and proceed – when the conflict is minor or tangential, and disclosure is sufficient to maintain reader trust. Example: covering a statewide program where the editor’s county is one of many jurisdictions analyzed.

2. Refer to an independent outlet – when the conflict is direct or substantial, the investigation is referred to an independent journalist or newsroom for right-of-reply outreach and publication. The Public Ledger provides the underlying data and methodology; the receiving reporter makes independent editorial decisions. Example: an investigation involving an entity connected to the editor’s family.

3. Pause the investigation – when no suitable independent outlet is available and the conflict is too substantial for disclosure alone. The investigation is placed on hold until the conflict is resolved or an independent partner is identified.

Active Disclosures

The following conflicts of interest are currently active and disclosed:

Editor candidacy

Zach Beaudoin is a candidate for Erie County Legislature, District 11. Any investigation where Erie County governance is a direct subject carries a prominent disclosure. The research and data analysis that form the basis of this project predate the campaign. No editorial decisions are made to benefit any campaign.

Referred investigations

The following investigations have been referred to independent outlets due to conflicts of interest:

These individuals’ findings will not be self-published by The Public Ledger. The receiving outlet handles all right-of-reply outreach and editorial decisions independently.

Review Cadence

• Every new investigation: Before work begins, the editor reviews whether any COI exists with subjects likely to be named
• Every new contributor: Before byline assignment, the contributor discloses all potential COIs
• Before publication: The pre-publication checklist includes a COI review step
• Ongoing: If a new conflict emerges during an investigation (e.g., the editor files for office), it is disclosed immediately and the recusal procedure is applied

How to Report a Conflict of Interest

If you believe The Public Ledger has an undisclosed conflict of interest, contact us:

• Email: editor@thepublicledgers.org
• Subject line: “Conflict of interest concern: [investigation name]”

We take these reports seriously and will respond within 72 hours.