✅ Do No Harm Checklist

Purpose: To ensure that EU-funded media support strengthens, rather than unintentionally endangers, partners’ safety, independence, and credibility. Apply this checklist during programme design, grant management, and visibility planning.

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🧩 1. Risk Assessment

Area	Key Questions	Action Points
Political	Could the partner be exposed through public association with the EU or Member States?	Include a risk matrix in programme design. Enable visibility waivers.
Digital	Are communications and reporting tools secure for partners?	Use encrypted channels, anonymised reporting, and data minimisation.
Legal	Could funding or content fall under restrictive media or NGO laws?	Obtain local legal insight; plan for compliance support or legal aid.
Reputational	Could donor branding or messaging undermine perceived independence?	Keep messaging low-profile; prioritise safety over visibility.

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🛡️ 2. Safety & Protection

Dimension	Minimum Safeguard	Enhanced Practice
Physical	Include safety training and protective equipment in budgets.	Support local safety networks and hotlines.
Digital	Fund cybersecurity tools and secure hosting.	Provide shared cloud or backup infrastructure.
Legal	Cover legal defence and anti-SLAPP costs.	Pre-approve emergency legal response protocols.
Psycho-social	Recognise stress and trauma support as eligible costs.	Offer optional access to professional care or peer networks.

“The biggest danger is the leak of information… security is very essential. That is why we anonymise beneficiaries and make reporting as simple as possible. Donors should be flexible and trust the implementer.”

- Representative of an EU Ministry of Foreign Affairs

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🔄 3. Visibility & Communications

Principle: Visibility should never come at the expense of safety or credibility.

Do	Don’t
Negotiate visibility requirements before signing contracts.	Assume that all partners can safely display EU logos.
Approve visibility waivers where needed and record them in “harm logs.”	Publicise sensitive partnerships on social media or at political events.
Use aggregated reporting and anonymised case studies for impact storytelling.	Rely on photo opportunities or embassy events in high-risk settings.

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⚙️ 4. Compliance & Burden Reduction

Area	Good Practice
Reporting	Scale requirements to grant size and partner capacity. Use joint templates across DGs.
Audits	Accept pooled or shared audits; avoid duplicating checks.
Coordination	Share calendars, risk assessments, and learning across EU actors.
Feedback	Create confidential partner feedback loops to detect risks early.

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🌐 5. Independence & Integrity

Objective: Safeguard editorial autonomy and public trust.

• Include independence clauses or side letters in all grant contracts.

• Separate donor communication goals from editorial agendas.

• Recognise that editorial independence and audience trust are security assets—part of Europe’s epistemic and democratic resilience.

• Avoid programme designs that incentivise content alignment or donor-driven narratives.

“For content specifically paid for, there is attribution to the EU, in print, radio, or TV, it will state ‘with support from the European Union.’ But for articles written by trained journalists on their own initiative, there is no attribution, because our investment was in their capacity, not the content.”

- EU delegation representative

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💡 Reminder “Do no harm” applies to the whole system, not only to individual organisations. Assess how donor visibility, funding patterns, and market interventions may influence the overall information ecosystem.