Arts Council England risk guidance draws criticism over perceived threat to creative expression
The criticism levelled at Arts Council England this week highlights the sensitivity that organisations face in making statements on political and social issues.
The non-departmental public body published a new relationship framework, including risk monitoring guidance to the organisations that it funds. It covers investment, governance and management, financial viability and reputational risk.
The document sets out the governance expectations of organisations funded by Arts Council England in identifying and classifying risk issues. It includes recommended management processes for a risk event and the Arts Council England's audit processes for managing third-party risk.
The section on reputation risk has raised the ire of the creative community, with a single paragraph being called out as overreach and a form of censorship.
“The type of action or activity that may constitute or influence an increase in reputational risk can include, but not be limited to, allegations of fraud or corruption, legal and compliance issues, failure to uphold best practice in relation to equality and diversity, financial concerns, issues with artistic and creative output that might be deemed controversial, activity that might be considered to be 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.”
The guidance raises the issue of organisations that the Arts Council England funds speaking out on political and social issues. I’ve written a lot about this recently. It has become acute for organisations of all kinds because of culture wars and polarisation.
Critics of the guidance claim that the implied threat from the Arts Council England is that organisations that take a position on social or political issues will have their funding cut. It has subsequently issued a statement reassuring its community and stating the importance of freedom of expression.
“[…] our guidance does not seek to stop any artist or organisation from making the art they want to make, or speaking out in any way they wish – including in ways that challenge institutions and authorities.”
The Arts Council England statement asserts the importance of robust risk management and issues related to an organisation taking a position on a controversial issue. This issue of when to take a stand versus when to remain silent is one of the most challenging contemporary issues in corporate communications.
Ironically, Arts Council England has faced a reputational issue in its attempt to provide guidance on reputational risk. A better approach would have been to engage stakeholders in the process and publish the new document alongside some of the high-profile organisations it funds.