Section 3

How to create an EDMF

These steps explain how to create your Ethical Decision-Making Framework for Communications. While they’re listed in order, some will happen concurrently. This is particularly the case for consultation, which should happen throughout the process. Working through these steps is useful even if you are integrating your EDMF into an existing policy.

Step 1: Reflect on your values

“How do our organisation’s values affect our storytelling?”

First, reflect on your organisation’s values. Your values (such as compassion, honesty and justice) guide your organisation’s actions. ‘Ethical action’ happens when your actions align with your values. Your values are not your policies or procedures. Your values explain how and why your organisation does what it does.

Your reflection exercise may involve a group of staff from across the organisation. Consider how your organisation’s values relate to storytelling and communications. Consider why your organisation chose these values. You can reflect on:

Step 2: Review your current policies

“How do we ensure our stories are ethical?”

Next, review your organisation’s existing policies, guidelines, procedures and external commitments that relate to ethical storytelling and communications. Identify any gaps or weaknesses that can increase the risk of unethical and unlawful communications. 

Assess whether your current policies, guidelines, procedures and external commitments are actually being followed and met. For example, your informed consent process and story/image storage system may need review. You may want to review these policies, where appropriate:

  • Communications Policy
  • Image Policy
  • Child Safeguarding Policy
  • Privacy Policy
  • Risk Policy
  • Disability Policy
  • Gender Equality Policy
  • Staff Code of Conduct
  • Staff Selection and Recruitment Policy
  • Reconciliation Action Plan

Step 3: Risk assessment

“How does storytelling create risks?”

Identifying risks associated with your communications, and the strategies to mitigate them, is an important step in the development of your EDMF. Review all communications activities and operations and consider the potential risks they pose. This could be achieved through team workshops, establishing a multi-disciplinary working group, or possibly by engaging an external expert to contribute to this assessment. It is helpful to have a range of personnel involved.

The following questions will help you to identify potential risks. It is not an exhaustive list and there may be other areas of your operations that you need to consider.

  • What consequences could individuals or groups face for contributing to your communication materials? Are the potential risks greater for certain groups or individuals that you work with? Do existing procedures help mitigate these risks?
  • Are there clear procedures in place for how content is collected and approved before publishing? Are existing procedures being followed consistently?
  • What risks do current processes for storing and filing images and information pose to your organisation or contributors, including children?
  • Are your policies and procedures well-understood and implemented by personnel involved at different stages of the communications process?
  • What role do partners or other third parties have in your communications process? Do they have the knowledge, capacity and experience to implement any relevant policies or procedures?
  • What areas of your operations are higher-risk and therefore likely to require additional checks and monitoring?
  • Are there risks to the well-being of staff or volunteers as a result collecting or being involved in communications work?
  • What risks could the sharing of material from third parties (e.g. news outlets) have for your organisation?
  • What are the potential reputational risks created by your communications materials?
  • Has your organisation had complaints or issues with its communications materials in the past that you can learn from?

Higher-risk activities may require more comprehensive procedures to be developed. These include:

  • responding to humanitarian emergencies
  • operating in regions with active conflicts and/or health epidemics
  • advocating on highly political issues; and
  • working with communities with intergenerational trauma, sexual violence and family violence.

A risk rating matrix, such as the following, can be used to assess the level of risk, as relevant for your organisation:

Step 3

Consider how you might mitigate any risks. You might need to:

  • Assess the effectiveness of existing policies and procedures
  • Include strategies in your EDMF or other documents to address or reduce identified risks
  • Have effective complaints handling procedures in place

It can be helpful to conduct a SWOT analysis (strengths, weaknesses, opportunities and threats) for your communications activities. Tools4development have a general risk assessment template suitable for a smaller organisation that you can download.

When completed, your EDMF should help cultivate the organisational culture necessary to maintain ethical communications of the highest level and mitigate potential risks.

Step 4: Consultation within the organisation

“Who can help develop our EDMF?”

Identify key stakeholders for participation in the EDMF development process. Ideally, participation will include staff from across the organisation (for example, programs, communications, marketing and fundraising). This will depend on the size and nature of your organisation. It may also make sense to have a working group with key staff that develop the EDMF then lead its implementation across the organisation.

Work together to define the objectives and purpose of the EDMF for your organisation. Consider the issues to be addressed within the EDMF, as well as the process for developing it.

Consider how you will involve your governing body or relevant subcommittee (for example a risk committee) in the development phase of your EDMF, instead of just at the review and approval stage. Governance members are affected by policies relating to communications (for example, being a spokesperson for the organisation), and can also have a keen interest in the prevention of the particular risks relating to communications. They may also be involved in other organisations that have good practice examples of how to address these risks.

Consider how you might engage your overseas staff and/or implementation partners to gain an insight into cultural understandings of the different aspects of ethical storytelling. Consider their practices and capacity to implement the policy to the standards required.  

If you work with particular communities, such as Aboriginal and Torres Strait Islander people or people seeking asylum, you may wish to consult with representatives who can express these people’s particular concerns and desires concerning storytelling.

Step 5: Consultation with partners

“How will our partners be affected by our EDMF?”

Consult outside your organisation to inform your EDMF. For example, you can consult with other NGOs, your partner organisations, external fundraising contractors, and other affiliates of your international networks.

Discuss potential risks, requirements and practical implementation with members of your international networks. Consider how appropriate risk management will be demonstrated and how incidents would be managed in these situations where there could be differing requirements across different legal entities and legal jurisdictions.

Step 6: Drafting your EDMF

Your organisation’s EDMF should be tailored to its specific needs. You can create a standalone Ethical Decision-Making Framework for Communications or you can add your EDMF to your existing Communications Policy. Section 4, an example EDMF, explains what you might include in your EDMF. 

Consider your stakeholder groups when designing the format of your policy. For example, some sections may need to be translated or converted to images. Consider how your EDMF will translate in other countries and cultures.

Your EDMF will need to be approved by management, and it may need to be signed off by your governing body. High-level approval shows your EDMF is expected to be embedded in the culture of your organisation.

Step 7: Socialising and implementing your EDMF

After finalising your EDMF, it’s important to consider how to share it with your key stakeholders. Your approach will vary, depending on the nature of your operations. You might consider:

Staff, contractors, governing body members and volunteers:

  • Include relevant clauses in employment or engagement agreements, and your Staff Code of Conduct
  • Key aspects of the EDMF and other relevant policies and procedures are included as part of induction training for new people and incorporated into regular training thereafter (e.g. part of an annual training package)
  • Provide staff with easy access to key operational aspects of the policy (for example, include an EDMF one-pager on the staff intranet, on posters in the office, or as part of key internal controls, such as when uploading content to online databases).

Consultants and suppliers:

  • Include relevant clauses in contracts with explanations of ethical storytelling
  • Explain ethical storytelling to consultants as part of their engagement process
  • Depending on the nature of their consultancy, consider providing consultants with some ethical storytelling training.

Implementing partners:

  • Provide a copy of the EDMF at the outset of the relationship
  • Where applicable, based on the relationship with the partner, provide training to key partner staff on the EDMF and your expectations.
  • Include ethical storytelling requirements as part of any partner due diligence and communicate expectations
  • Include ethical communications clauses as part of any contract and partnership agreements

Affiliates in international networks that receive funding:

  • Include ethical storytelling clauses as part of any contracting and partnership agreements
  • Provide a copy of the EDMF at the outset of the relationship and explain your expectations.

Donors that provide restricted funds:

  • Provide a copy of the EDMF and other relevant policies (for example, your Communications Policy), including an explanation of applicable areas.

Supporters and the general public:

  • Consider publishing your EDMF on your website.

Step 8: Monitoring and review

The EDMF should also have a set review schedule (e.g. every two years) to consider any updated regulations, learnings from incidents, stakeholder feedback and changed ways of working.

Consider creating an accountability framework for your EDMF and storytelling and publishing processes. You may choose to establish a working group, which regularly reviews your processes, outcomes of content-gathering field trips and published content. You may also choose to create practical checklists for stakeholders who are involved in the storytelling and publishing process to ensure they understand their responsibilities, if these don’t already exist.