Amid allegations of political interference at Voice of America, a Trump ally who heads the outlet’s parent agency has issued restrictive policy guidelines on conflicts of interest that would require journalists who are publicly critical of government agencies to recuse themselves from covering that agency. As an example, it says journalists who “like” a social media comment that “disparages the President” should recuse themselves from covering Donald Trump.

On Sunday afternoon, VOA staff were sent a memo on the policy dated October 2 by Michael Pack, a former conservative filmmaker who is currently the CEO of the U.S. Agency for Global Media, or USAGM, the agency that oversees VOA. Pack was previously a close associate of former White House adviser and far-right activist Steve Bannon. The memo, which was first reported Sunday night by NPR, was accompanied by an updated “social media policy” that reflects Pack’s guidance.

The Intercept spoke with three VOA journalists about the memo, all of whom requested anonymity because they are not authorized to speak publicly. The three journalists said the policy had sparked immediate concern that such a broad definition of “conflicts of interest” could be used to target journalists whose coverage VOA management deemed too critical of the Trump administration. Two of the journalists also expressed concerns that Pack’s guidance ran afoul of the agency’s “firewall” — a legal requirement that VOA remain free from government interference, including from USAGM.

A spokesperson for USAGM did not respond to multiple requests for comment.

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All three journalists also described an increasingly aggressive internal review process, in which VOA managers review rank-and-file journalists’ coverage for evidence of political bias. On Sunday, NPR reported that VOA’s longtime and scrupulously neutral White House reporter Steve Herman was the subject of such an internal investigation into whether his coverage of the White House was biased. Two journalists at VOA told The Intercept that a number of other investigations have taken place of less high-profile reporters, often resulting in reporters being told to provide more airtime for right-wing viewpoints.

“Conflicts of interest are not limited to those involving the recipient of money, ownership of stock, or gifts. The rule is broader,” the memo says. “Simply put, it is a conflict of interest for a journalist to participate personally and substantially in reporting on an issue: (1) in which they have a personal interest or (2) have publically personally expressed a political opinion.”

The conflict of interest policy outlined by Pack goes further than typical journalistic ethics policies, which usually stress neutrality or objectivity but do not characterize voicing a single opinion as a conflict.

The memo goes on to say that public criticism offered on any issue is grounds for recusal from reporting on that issue. The memo offers as an example if a VOA journalist “publicly criticizes the U.S. Department of Justice’s leadership for, among other things, implementing the policies and protecting the prerogatives of the Administration,” they “must recuse themselves from reporting on the Department and the part of the Administration implicated by the criticism.” The memo also says that staff should not cover any issue in which they are affected by government policy, giving the example that J-1 visa holders should “recuse themselves from any story involving J-1 visas.”

The memo cites the New York Times’s Ethical Journalism Handbook and the Washington Post’s “Policies and Standards” Page, which respectively contain language about “neutrality” and “fairness.” But the CEO’s memo turns minor violations of journalistic objectivity — a malleable concept to begin with — into a punishable offense. And, against the backdrop of Pack’s tenure at USAGM, employees worry that the broad standard lays a groundwork that could be used to punish journalists or water down coverage of the Trump administration.

One VOA journalist told The Intercept that “this new guidance is so vague and so broad that it could be used to silence journalists for covering almost anything within their own countries. … If a journalist working in the U.S. on a J-1 visa can’t cover the J-1 visa issue, can a journalist in America who breathes air not cover policy about clean air?”

The memo goes on to say that public criticism offered on any issue is grounds for recusal from reporting on that issue.

The memo says that other behavior, like “liking” a comment on Facebook, can be scrutinized as well. “For example, a journalist who on Facebook ‘likes’ a comment or political cartoon that aggressively attacks or disparages the President must recuse themselves from covering the President,” the memo says.

Bill Grueskin, a professor of professional practice at Columbia Journalism School, told The Intercept by email that conflict of interest policies typically define a “conflict” more narrowly. He gave examples like holding stock in a company you cover or having a spouse at the agency you cover.

“We can all be personally affected by almost any government action, whether it’s adjusting Social Security contributions or living near a national forest,” Grueskin wrote. “By setting such vague standards, VOA is opening up the possibility that these policies will be enforced arbitrarily, to harass reporters who don’t fall in line with the agenda their bosses are pushing.”

Pack’s memo has also raised concerns about VOA’s “firewall,” a policy that exists to protect VOA from outside government influence. VOA’s firewall is written into its congressional charter. Passed into law by the 1994 Broadcasting Act, the firewall “prohibits interference by any U.S. government official in the objective, independent reporting of news … free of political interference,” VOA’s website says. “The firewall ensures that VOA can make the final decisions on what stories to cover, and how they are covered.”

Thomas Kent, a former president of Radio Free Europe/Radio Liberty who also teaches at Columbia University, told The Intercept that the networks under USAGM, including VOA, have an obligation to set policies for fairness and neutrality. “The law says that the government and the head of USAGM should not be making editorial decisions and must respect the editorial decisions of all the networks. In that sense, I think that a memo of this sort should be coming from the heads of the networks, not the head of USAGM,” Kent said.

According to NPR, Pack’s memo has already been the subject of a whistleblower complaint filed by the Government Accountability Project alleging that it violates the VOA firewall by telling VOA leadership how to assign reporters to different stories and beats.

“The firewall is very clear. The USAGM CEO is not supposed to be sending out any kind of messaging about how news should be covered — how and by whom,” said a journalist interviewed by The Intercept. But another didn’t agree, saying that it was within Pack’s purview to send “best practices,” not specific instructions, for journalists to abide by.

One VOA journalist told The Intercept that the memo will contribute to a “culture of fear” under Pack and that employees have worried their past social media “likes” might come under scrutiny. “This feels like they are going after us,” the journalist said. “The example that was given in the letter was quite specific. It’s certainly making a lot of people nervous, including myself.”

Since Pack became the head of USAGM in June, he has been accused of trying to politicize coverage at VOA. Shortly after his confirmation, he fired the heads of four media organizations under USAGM’s purview, including the heads of Radio Free Europe, Radio Free Asia, and the Middle East Broadcasting Networks. Pack later gave an interview with pro-Trump news outlet The Federalist, in which he speculated that the groups he oversaw would be “a great place to put a foreign spy” — a comment some in VOA thought could subject their overseas colleagues to reprisals. And in the same interview, while stressing that he would not tell specific journalists what to report, he nonetheless said it was his job “to drain the swamp, to root out corruption and to deal with these issues of bias.”

Pack’s comments caused controversy at VOA, and a group of 14 journalists at VOA signed a letter denouncing the actions and remarks about spies. One source told The Intercept that Pack’s past comments are an important factor in how VOA employees are viewing the new guidance.

“Given Pack’s past comments saying that there is an inherent left-wing bias in VOA and … that his job is to correct that bias, this kind of sudden emphasis on our social media policy very much makes me think that they’re looking at some of our social media profiles online to substantiate those claims.”