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Updates to Arts Council England's policies warn that "political statements" made by individuals linked to an organisation can cause "reputational risk" and breach funding agreements.

A person posting on social media


Arts Council England (ACE) has told National Portfolio Organisations (NPOs) and Investment Principles Support Organisations (IPSOs) to be wary of "overtly political or activist" statements made in a personal capacity by people linked with them as this might expose them to “reputational risk” and breach their funding agreements.

In a series of updates made to its Relationship Framework policies on 25 January, ACE informed organisations to be alert to the risk of making “statements, including about matters of current political debate”, that are likely to result in a negative reaction from the public, media or stakeholders, towards the organisation or to ACE itself.

ACE said in a statement that it "expects all our funded organisations to support freedom of expression" and that changes were developed "in response to requests for further guidance on managing risk". But concerns have been raised that the move represents an attempt to "silence" arts organisations.


The guidance states: "Reputational risk can be generated not just by the organisation and its decisions but also by staff and other individuals associated with the organisation acting in a personal capacity."

In a list of examples that might increase reputational risk, ACE includes “activity that might be considered overtly political or activist and goes beyond your company’s core purpose and partnerships with organisations that might be perceived as being in conflict with the purposes of public funding of culture".

Writing on X, Marcus Berdaut, Artistic Director of anti-racist theatre company THE UPSETTERS, said: “Not only are they [ACE] trying to silence organisations but also people operating in a personal capacity too.”

In its guidance, ACE says: “For the avoidance of doubt, we expect all NPOs to support freedom of expression," adding that it is “essential for a thriving cultural sector in this country".

It stresses that "any activity" undertaken by an organisation can bring reputational risk to ACE, "regardless of whether the activity is directly funded through [its] grant or not".

ACE records risks at least every three months - or as they arise - and makes its risk assessment available to NPOs through its application portal, Grantium, on a quarterly basis. It uses this risk level - based on activity, investment principles, governance, financial viability and reputational risk - to determine whether to change its relationship with an organisation and whether further interventions or additional conditions to the funding agreement are needed.

Reputational risk

Organisations are urged to evaluate a series of updated prompts when considering an activity that could cause reputational risk. These include checking if the action is compliant with charity law, that it is consistent with ACE's Inclusivity and Relevance Investment Principle and whether there are any safety or security risks associated for staff or audiences.

The changes also include assessing if there is "likely to be" any damaging press of social media coverage and whether individuals working for the organisation have failed to comply with its social media policy. 

Included in the new guidance are four practical steps organisations can take when considering activities that may result in reputational risk, the final one of which is to "alert the Arts Council, via your Relationship Manager, of the risk and of your actions".

In a statement, ACE said: "Updates to the ‘monitoring risk’ part of our relationship frameworks were developed in response to requests for further guidance on managing risk. The purpose of reviewing reputational risk is to ensure that organisations and their boards are well placed to support staff and creative practitioners making decisions and delivering any activity that they have identified as ‘high risk'."

Political activity

The guidance on "political statements" comes in the wake of ACE-funded organisations facing criticism over their handling of issues relating to the conflict in Israel and Palestine.

Last month, Collections Trust, an IPSO that works with museums, libraries, galleries and archives to improve the management and use of collections, announced it would review its policy on linking to third-party resources following complaints over descriptions of Hamas found in a third-party terminology guide cited on its website. 

A few days later, Arnolfini Gallery in Bristol, an NPO, issued an apology expressing "regret" over its decision to withdraw from hosting two planned events as part of the Bristol Palestine Film Festival in November. Explaining its original decision to drop the events, Arnolfini cited the “difficulty for arts charities hosting events that might be construed as political activity”.

At the time, ACE did not comment other than to note that its funding recipients are "responsible for their own operations, including artistic programme decisions and day-to-day management of their activities".

It added: "The safety of people working in and visiting arts and culture venues must come first. We encourage any organisation with concerns to follow appropriate guidance."

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The lessons of the Holocaust are among the most important lessons of the last century. It was the most egregious example of anti-semitism and anti-humanity. These lessons have continued to be ignored - in Rwanda, Bosnia, Syria, Yemen, Myanmar and elsewhere - where we human beings have continued to show ourselves to be easily susceptible to the dehumanisation of others, and to be capable not only of the direct perpetration of terrible atrocities but also of our active complicity or silent consent. They are lessons for all of humanity, for each and every one of us. No one and no State excepted - including Israel.

Here is yet another example of the Arts Council all at sea. Over the years the Arts Council England has relaxed its rules for applications to become an NPO - charitabler status is not a prerequisite. At the same time organisations have been allowed to publish abbreviated accounts which give little information and transparecy is occluded. If all NPOs were registerd charities they would fall under the aegis of the charity commissioners of which the legal requirement to be a charity: "an organisation must be established for charitable purposes only, which are for the public benefit. An organisation will not be charitable if its purposes are political". Every NPO should be a registered charity and publish full accounts. It is that simple. If this was in place we would all have been spared yet more timewasting from Arts Council England.