Embargo policy.

Scope

This document covers the desk's embargo policy for press releases distributed under embargo. It applies to all embargoed releases regardless of sector, market, or account type. It covers how embargoes are defined, set, recorded, enforced, and lifted, and describes the desk's obligations and limitations in the event of a breach.

Definition

An embargo is an instruction from the client that the content of a release may be shared with named recipients before the agreed release time, but must not be published or otherwise disclosed before that time. Embargoes are a professional convention: they are not legally enforceable against journalists who receive the release in good faith and choose not to honour the embargo. The desk cannot guarantee that embargoed content will not be published early, and clients should brief the desk on this basis.

Setting an embargo

Embargoes are declared in the release brief. The client provides:

• The embargo lift time in UTC, with the equivalent local time for the primary target market noted
• Whether the embargo applies to all recipients or to a specified subset of the target list
• Any additional restrictions on the embargo period — for example, whether recipients may seek comment from third parties before lift

The desk confirms the embargo in writing before accepting the distribution assignment. Embargo times must be a minimum of two business hours from the intended lift time when the brief is submitted. Embargoes with less than two hours between submission and lift are not accepted unless agreed in advance with the desk head.

Embargo record

Each embargoed release is assigned an embargo record in the distribution system. The record notes: the release reference number, the client's authorised contact, the full list of recipients under embargo, the lift time in UTC, the desk editor responsible for the release, and the confirmation timestamp. The embargo record is locked — it cannot be amended after distribution to recipients without the client's written instruction and desk head sign-off.

Distribution under embargo

Embargoed releases are distributed to the agreed recipients with a cover note that states the embargo lift time in both UTC and the primary target market's local time. The desk does not send embargoed material to wire services or general distribution endpoints before lift. Where a release targets both embargoed and non-embargoed recipients — for example, a regulatory news service filing at lift time alongside advance briefings to named journalists — the two dispatch legs are managed separately and the timings are recorded independently.

Client obligations during the embargo window

During the embargo window, the client is expected to: not release the information through any other channel; not confirm the contents of the release to any party not on the embargo list; and notify the desk immediately if the embargo is at risk of being broken by circumstances outside the desk's control — for example, a leak or a competing announcement.

Embargo lift

At the agreed lift time, the desk initiates general distribution. The desk does not release early unless instructed in writing by the client's authorised contact. Where an early release is instructed, the desk confirms the revised lift time in writing before proceeding and updates the embargo record. The lift timestamp — whether at the agreed time or adjusted — is recorded against the release.

Embargo breach procedure

If the desk becomes aware that an embargoed release has been published before the agreed lift time, the following steps apply:

1. The desk notifies the client immediately with the outlet and, where known, the URL and publication time of the breach.
2. The desk and client agree within one hour whether to lift the embargo early for all recipients or to hold to the original lift time.
3. If early lift is agreed, the desk distributes to all remaining recipients immediately, with a note in the covering communication that the embargo has been lifted early.
4. The breach, the notification, and the lift decision are recorded against the embargo record.

The desk does not contact the breaching outlet to request removal of the article. That decision rests with the client. The desk will provide the client with the breach record on request.

Listed company releases

Embargoed releases for listed companies that contain price-sensitive information are subject to additional restrictions. Distribution under embargo to journalists before the regulatory news service filing is not standard practice for price-sensitive material. Clients seeking pre-filing briefings for listed company announcements should discuss the arrangement with the desk head before the brief is submitted. The desk will not distribute price-sensitive embargoed material without written confirmation that the arrangement has been reviewed against the client's legal and regulatory obligations.

Retention

Embargo records, including all correspondence related to the embargo and any breach, are retained for seven years from the release date. Clients may request a copy of the embargo record at any point within that period.

Effective: January 2026 · Next review: January 2027