ABOUT US

What we do must always be ethical.

What we do must always be legal.

The following protocols are how we ensure our two core principles. These protocols have been informed by discussions with our Advisory Board — including the former Editor-in-Chief of the Wall Street Journal, the founder of ProPublica, the first Public Editor of the New York Times, and numerous reporters — as well as conversations with members of our internal and external legal teams who have worked at the highest levels of the Department of Justice (DOJ), the Southern District of New York (SDNY), and the Securities and Exchange Commission (SEC). We did not seek input on these protocols from our investors.

These policies are essential. The info in these pages will be the difference between succeeding at Hunterbrook and failing. Study it. Master it. And as ProPublica writes in its Code of Ethics: “The most important wisdom about dealing with these questions is: When in doubt, ask.”

We do not lie, embellish, or exaggerate. We aim to write exactly what we know — no more, no less.

We believe in honest reporting. The only way we will sustainably grow is if our reporting is trusted. Accuracy is imperative. Thatʼs why every line in every article of ours will be fact-checked rigorously, copy-edited with the goal of ensuring there are no typos that distort meaning or demonstrate lack of quality, and given a final review by our editing team to ensure it meets our standards. We will also aim to make sure no key details have been omitted from the final article that we believe would meaningfully alter the reader’s view of our subject.

We tell readers not just what we know, but how we know it. That means attributing every new fact an article introduces — and being able to share its provenance. The only exception is anonymous sources (see policy below).

To whatever extent possible, we will also divulge the step-by-step process of our reporting in the article itself — often including a link to a methodology appendix, particularly when using Open Source Intelligence (OSINT).

We do not edit quotes or modify images in any way that could alter meaning. Data may be presented in more colloquial formats than the original, but the original should be included in the appendix. When we add accessibility features, these features must be strictly accurate. For example, the audio accompanying a satellite image must factually describe its contents, without any opinions; any uncertainty about what is pictured should be verbalized.

At Hunterbrook Media, we abide by the five traditional standards re: source relationships, adapted from the New York Times:

1) Financial Interactions: Donʼt pay sources, and donʼt let them pay you (or pay for you). Hunterbrook Media will cover any and all expenses incurred by staff during interactions with sources, provided they are approved by an editor. As The New York Times writes: “In some business situations and in some cultures, it may be unavoidable to accept a meal or a drink paid for by a news source. For example… reporter[s] need not decline every invitation to interview an executive over lunch in the corporationʼs private dining room, where it is all but impossible to pick up the check… A simple buffet of muffins and coffee at a news conference, for example, is harmless, but a staff member should not attend a breakfast or lunch [paid for by a source].”

2) Identity Disclosure: Employees must fully disclose their roles and disclose that information may be shared with Hunterbrook Capital, which in turn may make investment decisions based on the information provided. The only exception is if you’re seeking info that is available to the general public, in which case you may not need to affirmatively disclose your role as a reporter. (For instance, if you wanted to see how easy it would be to receive a prescription for a painkiller as an ordinary citizen, you wouldnʼt need to affirmatively share with the provider that you are a reporter.) A blurb we’ve been using: “I’m researching a story for Hunterbrook Media — a publication that may provide its research to Hunterbrook Capital, an investment firm.”

3) Use of Anonymous Sources: Anonymous sources should be avoided unless they offer indispensable info with no alternative to obtain it. In these cases, we require that the source consents to have their identity disclosed to our Publisher and our General Counsel, as well as the direct editor when appropriate. Identities of sources granted anonymity will be kept confidential unless we are legally compelled to disclose by the court of final jurisdiction, the standard of The New York Times, or unless the source later decides to waive confidentiality. It’s important to scrutinize and disclose any potential biases an anonymous source may have. As ProPublica writes in its policy: “To the extent that we can, we identify in our stories any important bias such a source may have. If the story hinges on documents, as opposed to interviews, we describe how the documents were obtained, at least to the extent possible. We do not say that a person declined to comment when he or she is quoted anonymously… We donʼt use composite characters or fictional ages, places or dates in our stories. Our default for identifying sources is by using full names; pseudonyms can only be used in extraordinary situations with the approval of the editor in chief or a managing editor.”

4) Source Diversity: Strive to talk to diverse sources, representing a wide array of opinions about the topic at hand; we want to cover reporting from every angle, not just one perspective.

5) Conflicts of Interest: If you feel like you have developed a conflict over the course of your reporting, share this with your editor, who will help you make a decision vis-a-vis recusal.

In addition to the standard guardrails on source relationships, our unique model restricts them in one more critical way: We try to avoid engaging with sources who are violating a fiduciary duty in order to speak with us (“insider sources”). There is more information on what a fiduciary duty is in our Compliance policy, but at a high-level, if someone has to break a confidentiality agreement, employment agreement, or breach their duties of trust and confidence with a company, in order to talk with you, you can’t talk to them in the first place.

Not using “inside sources” is, of course, the single biggest challenge of our reporting. It’s a big reason we are different from traditional reporting outlets. But with the rise of OSINT and the proliferation of Publicly Available Information (PAI), we believe important, meaningful reporting can be done without the help of a source inside a company.

The mission of our reporting at Hunterbrook Media is to make an impact — so as we are conducting investigations, we must always be considering which levers of change we are attempting to pull.

Our goal is to break stories that have market relevance. That’s precisely why it’s so important for us to maintain precision in our reporting and provide concrete evidence of our accuracy.

If passion conflicts with the truth, the truth wins. And if that means we have to kill an article, even one that supports a cause we strongly believe in, then that’s a price we’re willing to pay to uphold our commitment to telling the truth.

Humans have a tendency to run away from darkness toward sunlight. At Hunterbrook Media, we do the reverse. When deciding where to focus our reporting, our first question will always be: What is inadequately covered?

We donʼt chase clicks. Our goal is to enlighten, not entertain. Focus on how much new info we can bring to light.

We also don’t aggregate.
Write what only you can write. As Matthew Winkler argues in The Bloomberg Way: “News is a surprise. What did we know today that we didn’t know yesterday? That question will offer guidance when deciding which facts to highlight.”

Put simply, if it’s illegal, don’t do it.

As the New York Times writes in its ethics policy for reporters:

They may not break into buildings, homes, apartments or offices. They may not purloin data, documents or other property, including such electronic property as databases and email or voice mail messages. They may not tap telephones, invade computer files or otherwise eavesdrop electronically on news sources. In short, they may not commit illegal acts of any sort.

Our strength lies in our diverse experiences, backgrounds, and perspectives, enabling us to see what others miss.

Every company benefits from diversity but that is especially true of a company whose mission is to better understand the world. That is why we will seek to have a team of researchers that reflects the diversity of regions, sectors, and issues we hope to cover. At Hunterbrook Media, this isn’t a nice-to-have from a values perspective; it’s a need-to-have from a mission perspective. And we will be uncompromising in upholding this commitment.

If a potential future subject of a story offers to pay you anything, you canʼt accept. This includes offers to speak publicly at their conferences; to help with public relations; or to ghostwrite a book. We cannot be in the pocket of any of the subjects of our reporting.

If you create a book, movie, podcast, or newsletter separate from or following your time with Hunterbrook Media, you may identify Hunterbrook Media as a current or former employer. However, you cannot use your association with Hunterbrook Media as a platform to promote your product. For example, if you have written a book on a topic you are covering, you may not reference that book in the article.

Nothing is apolitical. If employees want to attend a protest or make phone calls for a candidate, we will not stop them from doing so, as long as they conduct these matters in their personal capacity, rather than as an agent of Hunterbrook Media — and as long as this activity doesn’t interfere with their ability to report on their beat.

Whenever possible, we will give the subjects of our reporting an opportunity to respond to it. This may take place before or after we publish. As ProPublica writes in its Code of Ethics: “Whenever we portray someone in a negative light, we should make a real effort to obtain a response from that person. We should give them a reasonable amount of time to get back to us before we publish. What is ʻreasonableʼ may depend on the urgency and competitiveness of the story, but we should do our best to make sure people are not surprised by what we write about them. If we donʼt reach the parties involved, we should explain in the story what efforts were made to do so.”

Weʼll go out of our way to avoid inaccuracies, but on occasion, we may make mistakes. When we do, we must correct them with urgency, contrition, and forthrightness — particularly if we got something wrong that altered the public’s understanding of a company or event.

The stakes of publishing inaccuracies at Hunterbrook Media are extremely high financially and reputationally — and consequences for errors will reflect that.

In general, abide by the axiom: “don’t do dumb shit.”

With this in mind, bring the same “donʼt do dumb shit” ethic we advise on social media to all of your communications. Everything you write or use in your reporting could one day end up public. Before sending, imagine your Slacks will be on the front page of a newspaper. Data security is also a paramount priority.

As the New York Times writes in its ethics policy: “Readers apply exacting standards to the entire paper. They do not distinguish between staff written articles and those written by outsiders. Thus as far as possible, freelance contributors… will be held to the same standards as staff members when they are on… assignments… If they violate these guidelines, they will be denied further assignments.”

Hunterbrook Media requires contractors to avoid conflicts of interest or the appearance of conflict.

As the New York Times writes: “Assigning editors should ensure that contributors are aware of this document, and to the greatest extent possible, [honor] its provisions while on assignment… Any disagreement over whether a specific provision applies to outside contributors should be resolved before the assignment proceeds.”