European Fact-Checking Standards Network (EFCSN)

VERIFIED MEMBERS

Membership in the EFCSN signifies an organisation’s rigorous commitment to provide accurate information ethically and transparently, without bias or prejudice and focus on matters in the public interest as well as a proven track record of excellence, integrity and accountability as definied in the European Code of Standards for Independent Fact-Checking Organisations.

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Knack

Website

https://www.knack.be/factcheck/

Date

09/02/2024

Please, answer the following questions:

Applicant

Date: 11/04/2023

The main goals of our fact-checking unit for the coming year are (1) to further optimize and streamline our workflow; (2) to filter and counter false information out of Flemish/Belgian public debate as much as possible; (3) to shape our fact checks in line with current scientific findings and recommendations as much as possible; (4) to strengthen our international network; and (4) to strengthen deCheckers, the national fact-checking network nonprofit. Founded in July 2021, deCheckers is a collaboration between journalists and fact-checkers, currently from Knack, public broadcaster VRT NWS, and Factcheck.Vlaanderen. deCheckers bundles fact checks in Dutch from different fact-checking outlets in one place for broader visibility and dissemination (website www.decheckers.be). deCheckers' social media manager manually tracks down mis/disinformation on social media, gently posts relevant fact checks in reply, and follows up the conversation. Via deCheckers - a form on its website as well as via the social media manager and tagging on social media - we install a new and extra channel for incoming suggestions for a fact check.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

The goals for the next year are clear and ambitious. Considering the upcoming elections in 2024, Knack will be an important stakeholder to provide trustworthy information about political programs and candidates, and to counter dis- and misinformation about the elections.

Article 2.2: Methodology

In order to be recognised as a verified member of the European Fact-Checking Standards Network (EFCSN), operations must:

Applicant

Date: 11/04/2023

We cover mis/disinformation that spreads in Flanders/Belgium / in the Dutch language. The topics we often deal with are health (e.g. coronavirus; and broader scope: well-being), climate change, or politics and policy issues. We also react to polarizing rumors that follow or precede news events, and the Russia-Ukraine war. The entertainment value of a fact check on a topic that appeals to a wide audience may also be a reason to fact-check less socially relevant claims. Because of the excellent story, but moreover, to attract new audiences to the format of fact checks with low threshold content.

Shannon Bakker (assessor)

Compliant

Date: 30/08/2023

From the body of work examined in this assessment it is clear that the statement above of Knack is correct. Most of what the Factcheckers of Knack publish is related to topics op public interest, such as climate change, the war in Ukraine and political unrest in France. There are also factchecks that seem to written mostly for entertainment value such as weather putting your head in the freezer helps against being tired. The research in the 'lighter' factchecks is just as thorough as the research on the more serious topics.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

The large majority of the factchecks of Knack focus on national and international topics in the public interest (politics, conflicts, health, science, ...).

Best Practices:

In addition to the required standards listed above, the Code identifies the following as a best practice that is encouraged but not required to join the EFCSN.

Article 3.1: Non-Partisanship and Impartiality

In order to be recognised as a verified member of the European Fact-checking Standards Network (EFCSN), operations must:

Applicant

Date: 11/04/2023

Here’s the link: https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

Scroll down to the subtitle “Onafhankelijkheid”.

As stated there, Knack Factcheck is an autonomous and independent form of journalism.

'Our ambition is to present truthful facts and reasonably defendable insights without the influence of any ideological agenda or bias. To ensure unbiased and neutral treatment of allegations, the journalists behind Knack Factcheck are not politically active. They participate in the political process as voters because they have that responsibility as a citizen, but they avoid the public expression of any political opinion whatsoever and try to avoid any appearance of bias.
We avoid and prohibit everything that might compromise the Knack Factcheck and our ability to work independently and honestly.'

Our internal policy is further outlined here: https://www.knack.be/redactionele-richtlijnen/

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

In the body of work I read for this assessment and in the information provided by Knack I found no prove whatsoever that Knack does not adhere to this policy.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

Overall Knack is transparent about and takes measures to guarantee non-partisanship and impartiality. The only thing they could me more clear about is what internal procedures exist to take action when bias/advocacy would be detected.

Applicant

Date: 11/04/2023

https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

Scroll down to the subtitle “Claimselectie”.

As stated there:

“Keeping balance - both thematically and ideologically - is a consideration in the decision-making process of whether or not to select a claim. We evaluate that balance regularly. It is partly quantifiable but also a matter of journalistic experience and intuition.”

We have selected the following fact checks to prove and illustrate our work:

(1) https://www.knack.be/factcheck/factcheck-nee-er-is-geen-plaats-te-veel-in-de-vlaamse-kinderopvang/

(2) https://www.knack.be/factcheck/factcheck-dat-limburg-slechts-1-procent-van-de-nmbs-investering-kreeg-is-onderschatting/

(3) https://www.knack.be/factcheck/factcheck-nee-vlaams-belang-zegt-niet-dat-het-4-miljard-euro-minder-wil-investeren-in-gezondheidszorg/

(4) https://www.knack.be/factcheck/factcheck-ja-strijd-tegen-fiscale-fraude-kan-8-tot-12-miljard-euro-per-jaar-opleveren/ - we publish fact checks about claims that prove to be true, too.

(5) https://www.knack.be/factcheck/factcheck-het-absenteisme-bij-bpost-bedraagt-geen-37-procent-of-15-procent-maar-1075-procent/

As for claims made by or related to politicians, these examples (1-5) illustrate that we do not concentrate our fact-checking on any one side of the ideological spectrum. We check outliers (1: Vlaams Belang, extreme right; 2: PvdA, extreme left) as well as rather mainstream politics (3: Vooruit, social-democrat; 4: Green Party; 5: N-VA, Flemish nationalist), and use the same standards and scrutiny regardless of who the claimant is.

(6) https://www.knack.be/factcheck/factcheck-een-kiwi-helpt-niet-tegen-slaapproblemen/ - we dig and lean on original sources for our conclusions and we employ scientific research and expert explainers as a standard.

(7) https://www.knack.be/factcheck/factcheck-nee-deze-foto-toont-geen-russische-generaal-majoor - we use online tools to show that pictures and videos can be used out of context and/or be manipulated to create mis/disinformation.

(8) https://www.knack.be/factcheck/factcheck-ja-uw-kat-herkent-uw-hoog-kattenstemmetje/

(9) https://www.knack.be/factcheck/factcheck-nee-coronavaccins-maken-geen-slapende-virussen-wakker/

In (8) we assess a rather light-hearted claim in comparison to (9). We use the same high standards of – scientific – evidence regardless of the subject at hand.

In (9) we assess a claim related to covid-19, which has been a dominant theme of our work since the pandemic.

(10) https://www.knack.be/factcheck/factcheck-nee-yuval-noah-harari-en-het-wef-willen-de-vrije-wil-niet-afschaffen/ - we react to rumors that can spread hate and conspiracy theories.

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

Knack has a policy that adheres to this practice. The evidence provided shows that Knack factchecks with the same scrutiny regardless of political orientation. In the body of factchecks I have read I've seen no proof that Knack focusses unduly on one side of the political spectrum.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

This practice is written in the applicant’s methodology and it can also be observed in their work and website.

Applicant

Date: 11/04/2023

https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

Link to guidelines to safeguard the independence and impartiality of our fact-checking operation and its likewise reputation: https://www.knack.be/redactionele-richtlijnen/

We have procedures in place to ensure these policies are being adhered to.

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

The policies described appears sufficiently clear to ensure compliance. I have found no breaches of this policy by the factchecking-editors

Sarah Van Leuven (assessor)

Needs more info

Date: 09/01/2024

The links for the public are rather general about the newsroom's editorial independence and impartiality, which are presented as central guidelines. There is no information on internal policies to make sure these policies are adhered to. In the proposal, Knack writes that procedures are in place to ensure these policies and guidelines are adhered to, but it is not clear what these procedures entail precisely. No examples are given.

Applicant

Needs more info

Date: 06/02/2024

If an employee makes a partisan statement in the operation's name, the employee is asked to explain how this has come about, and the partisan statement is removed immediately. The editor-in-chief once again stresses that the employee should refrain from partisan statements in the future.

Applicant

Date: 11/04/2023

https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

Link to guidelines to safeguard the independence and impartiality of our fact-checking operation and its likewise reputation: https://www.knack.be/redactionele-richtlijnen/

We have procedures in place to ensure these policies are being adhered to.

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

The policies described appear sufficiently clear to ensure compliance.

Sarah Van Leuven (assessor)

Needs more info

Date: 09/01/2024

Same as previous. It is clearly outlined in the editorial policy and guidelines that journalists cannot accept gifts or payments, but it is unclear which procedures are available to take action in case such a situation occurs.

Applicant

Needs more info

Date: 06/02/2024

In the case an employee accepts gifts, favors, or services that go beyond common social and courtesy items, the employee is asked to explain how this has come about, and disciplinary actions are taken so that this will not happen again in the future.

Article 3.2: Privacy and Safety

In order to be recognised as a verified member of the European Fact-Checking Standards Network (EFCSN), operations must:

Applicant

Date: 11/04/2023

As a rule, we name and identify the claimants of a claim under investigation and other sources that are mentioned in the publication. An exception to mentioning sources by name is when that would compromise their safety. Thereby we mean that full transparency about the identity of the source in the publication might irresponsibly jeopardize its physical integrity and/or mental well-being.

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

The policy is clear and I have found no evidence that Knack does not adhere to this policy.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

Knack factchecks typically focus on claims by powerful public actors or images/videos that circulate virally on social media. The focus on politicians and other people in powerful positions is in line with the general focus of Knack on political and international news and is in line with the watchdog role of journalism. What these powerful people say and do is typically part of the public sphere, and it is important to mention their names to inform people correctly. When it comes to images, the focus is on verifying the truthfullness of the images (if needed to warn people) rather than exposing the many accounts who share the footage. When scanning the website, I could not find examples of factchecks where the content of the factcheck could potentially harm the subjects of the investigation.

Applicant

Date: 11/04/2023

When we check claims made by average social media users, reckoning that they are not used to being at the center of media attention, we generally do not mention them by name and we obscure their image and/or identity by not showing it or blotting it out in the publication. By average social media users, we mean people or accounts without public resonance apart from their social media posts or claim under investigation.

However, we do call claimants by name when they are public figures or individuals well-known for redundantly posting misinformation. Redundancy is among other things measured by whether other qualitative fact-checking organizations have proven claims from that person to be untrue.

Examples of how we use generic terms to name ‘obscured’ sources are (1) “a Dutch-speaking Twitter account” (https://www.knack.be/factcheck/factcheck-nee-deze-video-van-een-windturbine-die-in-twee-kraakt-door-een-storm-is-niet-echt/); (2) “a Twitter user” (https://www.knack.be/factcheck/factcheck-nee-deze-video-toont-geen-ontploffing-van-een-elektrische-auto/); (3) “a Flemish man” (https://www.knack.be/factcheck/factcheck-nee-dit-is-geen-foto-van-klaus-schwab-op-de-g20-in-bali/)

However, for transparency reasons, we generally do not shield the profile names or pictures in hyperlinked archived versions of social media posts that are in play. That is our guideline, except for when subjects’ safety would be at stake (supra, 3.2.A).

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

The policy outlined is clear and I have found no evidence that Knack does not adhere to it's own policy. Knack clearly tries to find a balance between the privacy of 'normal' social media users and the need to be transparent about where social media posts come from.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

See also 3.2A

Applicant

Date: 11/04/2023

https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

As a first step in the investigation, we generally contact the sender of the claim, asking what source(s) the claim relies on and what it exactly means. We ask for the factual basis and documents or research on which the claim relies, requesting to see them for ourselves.

When (1) we have reached the saturation point in the investigation; (2) the claim appears to be false or inaccurate; and (3) circumstances require and admit it, referring for instance to speed and harmfulness, we (re)contact the source of an inaccurate claim for feedback, and subsequently integrate it in the fact check before publication.

Example: https://www.knack.be/factcheck/factcheck-geen-bewijs-dat-een-plantaardig-dieet-voor-meer-of-betere-erecties-zorgt/

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

It is clear from the body of factchecks that I read that Knack does try to reach out to any named claim maker before publication. This is the case for companies and public figures. 'Normal' social media users are generally not named.

Sarah Van Leuven (assessor)

Compliant

Date: 09/01/2024

good approach. Moreover, I do not think that it is needed or desirable to provide an additional platform by means of a right-to-reply to people who (repeatedly and intentionally) spread false information.

Best Practices

In addition to the required standards listed above, the Code identifies the following as a best practice that is encouraged but not required to join the EFCSN.

Article 3.3: Honest corrections

In order to be recognised as a verified member of the European Fact-Checking Standards Network (EFCSN), operations must:

Applicant

Date: 11/04/2023

In the 'about' section of Knack Factcheck we unfold our policy to address corrections. https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

Scroll down to subtitle “Hoe zetten we eventuele fouten recht”. This is the outline of our corrections and complaints policy:

Fact-checkers also make mistakes. Knack applies the principle that any errors are acknowledged equitably and corrected as quickly as possible in all due transparency.

Complaints and comments can be sent by e-mail to the editors of Knack Factcheck via [email protected].

Messages will always be read and handled by the author of the fact check after consulting with the fact check coördination team, and, if necessary, the editor-in-chief.

If the supplied argument and/or the additional information is such that the fact check has to be revised and corrected, we immediately revise the text online. In case of major errors, this revision is mentioned explicitly, so that it is clear to readers what went wrong. If it concerns a fact check that also appeared in the paper magazine, we publish a correction in the appropriate section in the next issue.

If the argument provided and/or the additional information is not crucial to the evaluation in the fact check but nonetheless relevant or useful, we will provide this information as an update at the bottom of the article.

In both cases - both the crucial and the other corrections and adjustments, the message 'updated on' appears at the top of the article with the hour and the date of the update.

What the update was and why it was conducted is stated at the bottom of the article.

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

The corrections policy adequately complies with this standard.

Applicant

Date: 11/04/2023

Example: https://www.knack.be/factcheck/factcheck-aandeel-van-het-transport-in-de-co2-uitstoot-van-voeding-schommelt-tussen-de-01-en-915-procent/

After significantly adjusting this fact check based on new information, we have, among other things, adjusted the conclusion, and reissued the fact check with our next newsletter, a channel through which the fact check was originally disseminated.

Unfortunately, currently, both newsletter(s) could in retrospect not be retrieved.

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

Knack explains quite clearly on it's methodology page how it deals with errors that are big enough to change the conclusion of a factcheck. The example provided illustrates that Knack adheres to this policy.

Sarah Van Leuven (assessor)

Needs more info

Date: 11/01/2024

Corrections are published both on the website and in print, depending on the publication channel. The example also refers to the distribution of a correction through a newsletter. What is unclear in the policy and example, is whether corrections are also communicated through Knack's social media channels, since these are also important gateways for audiences to Knack's factchecks, and social media audiences may remain unaware of corrections if they are not communicated through social media either.

Applicant

Needs more info

Date: 06/02/2024

We communicate any corrections there may be on all of our appropriate channels, be it in print, digital, or otherwise.

Best Practices:

In addition to the required standards listed above, the Code identifies the following as best practices that are encouraged but not required to join the EFCSN.

Article 4.1: Organisational transparency

In order to be recognised as a verified member of the European Fact-Checking Standards Network (EFCSN), operations must:

Applicant

Date: 11/04/2023

Knack Factcheck (https://www.knack.be/nieuws/factcheck/) is the distinct section and unit of Knack Magazine. Knack Magazine (www.knack.be) is a news outlet of the media company Roularta Media Group, a Belgian-listed multi-media group with over 1,300 employees and a total combined turnover of 300 million euros. Details on the company and its foundation are stated in the 'about' on the website of Roularta Media Group (https://www.roularta.be/en/about-roularta/our-company).

In the Crossroad bank of Enterprises (KBO), Roularta Media Group is registered by number 0434.278.896.

An oversight of shareholders, including the names of who holds more than 5 percent, can be found here: https://www.roularta.be/nl/roularta-op-de-beurs/het-aandeel/aandeelhoudersstructuur

Notification under the transparency legislation, the Act of 2 May 2007 on disclosure of major shareholdings, can be found here: https://www.roularta.be/nl/roularta-op-de-beurs/het-aandeel/wet-van-2-mei-2007-op-de-openbaarmaking-van-belangrijke

Shannon Bakker (assessor)

Compliant

Date: 09/10/2023

The information provided addresses all necessary elements to adhere to this standard.

Sarah Van Leuven (assessor)

Compliant

Date: 11/01/2024

Information about Roularta is not outlined on the website of Knack, but the necessary links to the Roularta website are provided on the web page that outlines all information about Knack's factchecks: https://www.knack.be/alles-wat-u-moet-weten-over-de-factcheck-van-knack/

Article 4.2: Financial transparency and conflicts of interest

In order to be recognised as a verified member of the European Fact-Checking Standards Network (EFCSN), organisations or parent organisations must:

Best Practices

In addition to the required standards listed above, the Code identifies the following as a best practice that is encouraged but not required to join the EFCSN.

I. ELIGIBILITY TO APPLY In order to apply to the EFCSN, your fact-checking operation must first meet the criteria outlined in Chapter 5.2 of the Code.

1. When and why was your fact-checking operation started?

2. How many people work or volunteer in the operation and what are their roles?

3. Please list any activities besides fact-checking that your operation engages in.

4. What are the goals of your fact-checking operation over the coming year?

5. Please explain the geographical scope of your fact-checking operation and how you fit the Code’s requirement to “have a substantial and demonstrable focus on one or more of the countries of the Council of Europe, Kosovo or Belarus”.

6. Please attach a list of an average of four original fact-checks per month from the past year if this is your first time applying to the EFCSN or from the past two years if you are renewing your application.

7. Please note which policies you have had to change, if any, over the past 6 months in order to comply with the Code.

2.A. Make available and easily accessible on their website an explanation of the process used to select, research and complete investigations, including a definition of any rating systems used.

2.B. Assess the merits of the evidence found using the same standards applied to evidence on equivalent claims, regardless of who made the claim.

2.C. Primarily focus on topics that are in the public interest, defined here as issues that concern the welfare of society or individuals, and be willing to explain, if requested by an assessor, how various investigations fit this definition.

2.D. Make available and easily accessible on their website a channel through which the public can submit possible claims for verification and encourage users to send claims to check, while making it clear what readers can legitimately expect will be fact-checked and what isn’t fact-checkable.

2.E. Identify and include in publications, when possible, access to all evidence or other required information for a reader to replicate the verification process.

2.F. Provide evidence for every pertinent factual statement made in an investigation, relying on primary sources where possible. Set out in its fact checks relevant evidence that appears to support the claim as well as relevant evidence that appears to undermine it.

2.H. Name all sources except when their safety is at risk. In such exceptions, anonymous sources may only be included if the information they provide is corroborated by named sources or material evidence.

2.I. When quoting experts, establish their credibility in the relevant topic.

2.J. Ensure each investigation undergoes at least one round of editing by someone other than the author before publication.

2.K. Present findings in precise, factual and non-emotive language, while taking care not to overstate conclusions.

2.K. Present findings in precise, factual and non-emotive language, while taking care not to overstate conclusions.

3.1.A. Be editorially free and politically independent.

3.1.B. Not endorse or advise the public to vote for any political parties or candidates for public office.

3.1.C. Not conclude any agreement or partnership with a political party or any other public relations and similar activities that could compromise the operation’s reputation for independence and impartiality

3.1.D. Not focus investigations unduly on one particular political party or side of the political spectrum.

3.1.E. Not employ anyone who holds a salaried and/or prominent position in a political party, government, state or public company under the direct control of a political party or government.

3.1.F. Explicitly address in publications any reasonable conflict of interest or political bias, including from experts or organisations cited.

3.1.H. Have internal policies that bar employees from accepting in a professional context any gifts, favours, or services with advantageous conditions that go beyond common social and courtesy items, and have procedures in place to take action if they do.

3.1.I. Make available and easily accessible on their website these and any other non-partisanship policies (See template in Annex 3)

3.1.J. Only advocate for issues that are relevant to the mission of fact-checking and are compatible with a reputation for independence and impartiality. Organisations that engage in advocacy must set out public guidelines on how they adhere to these standards.

3.2.A. Obscure the image and/or identity of subjects of an investigation when there is a reasonable concern for their safety.

3.2.B. Take measures to avoid exposing the source or identity of user-generated disinformation content to undue public scrutiny.

3.2.C. Be restrictive, respectful and considerate when mentioning or identifying minors and make efforts to protect their privacy.

3.2.D. Anonymise any personal information that could allow the harassment of people (i.e. at least partially concealing telephone numbers, IDs or passports, bank account numbers, email addresses…).

3.2.E. When appropriate and possible, a right-of-reply should be offered to any named person or organisation who is the source of the inaccurate claim and/or is the subject of significant criticism or allegations.

3.2.F. Put in place measures that aim to address the risk of trauma or harassment experienced by staff as a result of the operation’s activities, including but not limited to providing training to prevent and identify symptoms.

3.3.A. Correct every known mistake promptly with a correction note in the same publication in which the error was made; if the error is only typographical, grammatical or stylistic, a correction note is not needed.

3.3.B. When the original publication in which the mistake was made is not editable, disseminate the correction in the same format and channel as the original so that as far as possible users of the original see the correction and the corrected version.

3.3.E. Make available and easily accessible on their websites a corrections policy and a record of the corrections published over the previous year in the first application for EFCSN membership and of the previous two years upon renewal.

3.3.F. Include in their corrections policy, available and easily accessible on their websites, a detailed account of how they assess requests for corrections.

3.3.G. Offer audiences direct channels to request a correction, within the corrections policy on their website.

3.3.I. Undergo an internal and documented annual review of published corrections to determine whether methodological and procedural changes should be made to avoid repeating the same mistakes in the future.

3.3.H. Inform audiences of the possibility of submitting a complaint to the EFCSN under the terms of article 6 with a link to the complaint form.

4.1.A. Make available and easily accessible on their website a statement that sets out the applicant’s organisational structure and makes clear how and by whom editorial control is exercised.

4.1.B. Make available and easily accessible on their website regularly updated information related to the ownership and legal status of the operation and/or parent organisation. People or entities holding over 5% of the shares must be disclosed (see template in Annex 4).

4.1.C. Make available and easily accessible on their website regularly updated information related to the governance of the operation and/or the parent organisation (see template in Annex 5).

4.1.D. Provide proof of the ownership, legal status and governance of the organisation to the external assessors

4.1.E. Make available and easily accessible on their website regularly updated information about the identity of the editors or decision makers behind the operation, including any relevant previous roles.

4.1.F. Make available and easily accessible on their website regularly updated information about the positions held by all staff involved in the fact-checking operation’s editorial output, including any relevant previous roles.

4.1.G. Make available and easily accessible on their website a statement setting out the operation’s mission, values and internal guidelines in place to protect its independence.

4.1.H. Make available and easily accessible on their website the organisation’s bylaws, understood as the rules or statutes that govern the members of an organisation.

4.2.A. Disclose all income sources contributing 1% or 5.000 euros (whichever the higher), from the most recent annual accounts when joining and the last two annual accounts when renewing membership, to external assessors and the Governance Body

4.2.D. Make available and easily accessible on their website an updated declaration of all unpaid significant commitments made to other organisations (see Annex 9).

4.2.F. Make available and easily accessible on their website goods and services they receive from external sources, including paid subscriptions or free access to tools, software and/or advertising, that make a material difference to their finances (5% of net income).

4.2.H. Make available and easily accessible on or from their website the full annual accounts of their organisation for each year since joining the EFCSN.