SABC Editorial Policies 2020 About the Policies [Tall My In: Iguana: ra: - mah'?l - Mi?ii?i??' Table of Contents 1. Introduction 1 2. The SABC’s Mandate 2 2.1 2.2 2.2.1 2.2.2 2.2.3 2 2 2 3 3 3. The Editorial Code 3.1 3.2 4. Powers, Functions, Rights and Obligations Core Editorial Values The Constitution SABC as a Public Service Entity Core SABC Editorial Values 4 Editorial Responsibility and Upward Referral Mandatory Referral Policy on Programming and Publishing 4.1 Content Approach 4.1.1 Guiding Principles 4.1.2 Audience Engagement in Programming and Publishing 4.1.3 Taste, Decency, Hate Speech and Graphic Content 4.1.4 Audience Advisories 4.1.5 Screening of Films 4.2 Digital Content and Publishing 4.2.1 Production and Publication of Digital Content 4.2.2 User-Generated Content (UGC) 4.2.3 Digital Media Guidelines 4.2.4 Guidelines for Official SABC Digital Media Accounts 4.2.5 Guidelines for Personal Digital Media Accounts 4.3 Scheduling and the Watershed Period 4.4 Discrimination and Stereotypes 4.4.1 Disability 4.4.2 Race 4.4.3 Gender 4.4.4 Violence 4.4.5 Privacy, Dignity and Reputation 4.4.6 Grief, Suffering and Distress 4.4.7 HIV/AIDS - Medical Conditions 4.5 Children 4.6 Sex, Nudity and Pornography 4.7 Content Sponsorship 4.8 Infomercials 5 6 8 8 8 9 9 10 11 11 11 12 12 13 14 14 15 15 16 16 16 17 17 17 18 19 19 20 Table Of Contents 5. 6. Policy on News and Editorial Content 22 5.1 Introduction 5.2 Editorial Independence and Impartiality 5.3 Editorial Guidelines 5.4 Protected Comment 5.5 Language and Tone in News 5.6 Interviewing 5.7 Analysts, Experts and Specialist Commentators 5.8 Investigative Journalism 5.9 Paying for Information 5.10 Opinion Surveys in News Content 5.11 Protection of Sources 5.12 Gender, Children and Under-Represented Communities 5.13 Privacy and Dignity 5.14 Reporting on Suffering and Distress 5.15 National Events and Schedule Changes 5.16 Live Productions 5.17 Allocation of Resources 5.18 Universal Access to News Content 5.19 Guidelines for Equitable Treatment of Language in News 5.20 Election Broadcasts 5.21 Restrictions on Sponsorship of News-Related Content 22 22 23 24 24 24 24 25 25 25 25 26 26 26 27 27 27 28 28 28 29 Language Policy on Content 32 6.1 Introduction 6.2 Statement of Commitment 6.3 Aims and Objectives 6.4 Scope of the Policy 6.5 Language in National Events Coverage 6.6 Language in Content Offerings 6.7 Operating Principles 6.8 Language in Radio Content and Services 6.9 Content Guidelines 6.10 Language in News and Information Services 6.11 Language in Children’s Content 6.12 Allocation of Resources for Language Services 6.13 Language Services and Universal Access 6.13.1 Languages on Television 6.13.2 Guidelines for Equitable Treatment of Languages 6.13.3 Language Access and Television Content 6.13.4 Unilingual and Multingual Content 6.13.5 Language Access and Television News 6.13.6 Language Access and National Events Coverage 6.13.7 Language Access and Children’s Programmes 6.13.8 Language Access and Drama 6.13.9 Language Access and People with Disabilities 6.13.10 Language Access and Allocation of Resources 6.13.11 Languages and Universal Service and Access 6.13.12 Language Access and Research 6.13.13 Language Access and Technology 6.13.14 Relationships with other Organisations 6.13.15 Monitoring and Implementation 7. Universal Service and Access Policy 7.1 7.2 7.3 Context of this Policy Scope of the Policy Monitoring and Implementation 32 32 32 33 33 33 33 33 34 34 34 34 34 34 35 35 35 36 36 36 36 36 37 37 37 37 37 37 40 40 40 40 Table Of Contents 8. Policy on Local Content 42 8.1 Introduction 8.2 Requirements and Commitments 8.3 Scope of the Policy 8.4 Local Content on Television 8.4.1 Definition of Local Television Content 8.4.2 Definition of Independent Production 8.4.3 Local Content Quotas for Television 8.4.4 Television Compliance with Quotas 8.4.5 SABC’s Local Content Approach on Television 8.5 Local Content on Radio 8.5.1 Definition of South African Music 8.5.2 Radio Quotas for South African Music 8.5.3 Radio Compliance with Quotas 8.5.4 The SABC’s Approach to South African Music on Radio 8.6 Monitoring and Implementation 9. Policy on Religious Content 46 9.1 Introduction 9.2 Nature of Religious Content 9.3 Scheduling of Religious Content 9.4 Paid Broadcasting and Religious Content 9.5 Community Faith Committee (CFC) 9.6 Monitoring and Implementation 10. Policy on Educational Content 46 46 47 47 47 47 50 10.1 Introduction 10.2 Objectives 10.3 Key Principles 10.4 Scope of the Policy 10.5 Guidelines for Implementation 10.6 Guidelines for Scheduling Educational Content 10.7 Advertising and Educational Content 10.8 Public Mandate Aspects in Educational Content 10.8.1 Early Childhood Development 10.8.2 Children at Home 10.8.3 Formal Education 10.8.4 Youth Development 10.8.5 Adult and Human Resources Development 10.8.6 Public Education 10.9 Research to Support Educational Content 10.10 Monitoring and Implementation 11. Complaints Management Processes 11.1 11.2 11.3 11.4 11. 42 42 42 43 43 43 43 43 43 44 44 44 44 44 44 50 50 51 51 51 51 52 52 52 52 52 52 53 53 53 53 Complaints Lodged with the BCCSA Complaints Lodged with Advertising Regulatory Board (ARB) Complaints Related to Contravention of SABC Editorial Policies Complaints Related to Contraventions of the Press Code Review of the Editorial Policies 54 54 55 55 55 55 12. Acknowledgements 56 13. List of Acronyms 57 CONTENT THAT INSPIRES 1 1. Introduction In terms of Section 6 of the Broadcasting Act 4 of 1999 (the Act), the SABC is required to develop policies that are intended to ensure compliance with the Authority’s Code of Conduct, the Corporation’s licence conditions, and the provisions of the Act. The SABC’s Editorial Policies (the policies), covering news and editorial content, programming and publishing content, local content, educational content, universal service and access, language, and religious content, are to be submitted to the Independent Communications Authority of South Africa (ICASA) for compliance. This document is a compilation of the policies, which the SABC requires to guide it in discharging its public service mandate. The policies represent how the Board gives shape to and interpret the SABC’s public broadcasting mandate, and provide a framework for decision-making by editorial staff. The policies relate to all SABC content, and to services for both national and international audiences. They apply to all the services, irrespective of whether they are carried on radio, television or digital media. The applicability of the policies extends to both the SABC’s public and commercial services with varying intensity, depending on the specific issues being dealt with. Where they have particular relevance to either portfolio, this is stated. Where the policies refer to particular designations, these may change from time to time, and in the case of this happening, action flowing from the policies should involve the appropriate and relevant personnel at that time. The policies are intended to help all staff make informed decisions on editorial issues, so that distinctive, compelling and sometimes controversial content can be produced, scheduled, broadcast and published, while maintaining the highest ethical and editorial standards. All SABC employees, regardless of geographical location, are therefore required to study, understand and ensure compliance with these policies. The policies are also intended to inform stakeholders, suppliers and members of the public about the editorial positioning of the SABC, and how editorial decisions are taken. The SABC recognises that full compliance with its policies depends on the professionalism, competence, skills and commitment of its staff. On-going professional development of SABC staff is therefore a crucial part of the implementation of these policies. The SABC also assesses regularly the professional developmental needs arising from the implementation of these policies, in order to develop appropriate and on-going professional developmental programmes. The policies have been approved by the Board of the SABC after being developed by the SABC’s Policy and Regulatory Affairs Department, in collaboration with the heads of all the different programming services and platforms, after an extensive, public consultative process in line with the SABC’s public mandate. Questions on any aspects of the policies should be directed to the Policy and Regulatory Affairs Department at Policy@ sabc.co.za OR (011) 714-3927. Whereas certain policies apply to specific content and services areas, all the policies should be read together with Chapter 2: The SABC’s Mandate and Chapter 3: Policy on Programming and Publishing. All the informational and actuality content, whether it is produced by SABC News or not, should conform to the Policy on News and Editorial Content and the Policy on Content Programming and Publishing. 2 2. The 2.1 The SABC’s Mandate SABC’s Mandate Powers, Functions, Rights and Obligations The SABC’s mandate and objectives as a public broadcaster are defined by the Charter which is set out in Chapter IV of the the Act, and requires the SABC to encourage the development of South African expression by providing, in all official languages, a wide range of programming that: 2.1.1 Reflects South African attitudes, opinions, ideas, values and artistic creativity; 2.1.2 Displays South African talent in educational, informative and entertainment content; 2.1.3 Offers a plurality of views and a variety of news, information and analysis from a South African point of view; and 2.1.4 Advances the national and public interest. The SABC’s powers and functions, as well as its rights and obligations, are derived from a number of sources in addition to the Charter, namely: 2.1.5 Legislation; 2.1.6 The licence conditions of all the SABC’s broadcasting services platforms, and regulations issued by ICASA from time to time; 2.1.7 The Code of Conduct for Broadcasters administered by the Broadcasting Complaints Commission of South Africa (BCCSA); and 2.1.8 The Press Code administered by the Press Council and the Press Ombudsman. South Africa’s broadcasting legislation provides for a three-tier licensing structure for broadcasting services: public, commercial and community. The SABC is South Africa’s only public service media entity, and for public accountability purposes consists of two separate divisions controlled by the Board: a public service division and a commercial service division, in each of which the SABC runs a number of radio stations, television channels and digital platforms. Each has a set of licence conditions that imposes obligations, including quotas for local content, and requirements for geographical coverage and language services. These are laid down by ICASA in the compliance Procedure Manual of 2011, which is used for monitoring compliance with the licence conditions, and the objectives of the Charter. Like all other public service media, the SABC is required to adhere to a Code of Conduct for Broadcasters that is approved by ICASA. As a member of the National Association of Broadcasters (NAB), the SABC is subject to the rules of the BCCSA which ensures that broadcasters adhere to certain minimum standards of broadcast content. Also, owing to its bouquet of digital platforms, the SABC is a member of the Press Council which ensures adherence to minimum standards of digital media content. A central tenet of the SABC’s Charter is that it enjoys freedom of expression and journalistic, creative and programming independence. The SABC Board, which is appointed by the President of the Republic of South Africa on the advice of the National Assembly, controls the affairs of the SABC and is mandated explicitly to protect the Corporation’s freedom and independence as set out in the Charter. 2.2 Core Editorial Values Public service media worldwide share many features relating to independence, accountability and diversity. However, in the context of the SABC, there are unique facets that also determine its positioning. These relate to South Africa’s challenges as a relatively young democracy and a society in transition. 2.2.1 The Constitution These challenges are captured neatly in the preamble to the Constitution, which sets out the objectives of the South African constitution being to: 2.2.1.1 heal the divisions of the past and establish a society based on democratic values, social justice and fundamental human rights; 2.2.1.2 lay the foundations for a democratic and open society in which government is based on the will of the people and every citizen is equally protected by the law; 2.2.1.3 improve the quality of life of all citizens and free the potential of each person; and The SABC’s Mandate 2.2.1.4 build a united and democratic South Africa able to take its rightful place as a sovereign state in the family of nations. 3 to make editorial decisions on programming, scheduling and publishing content. 2.2.3.3 Nation-Building 2.2.2 SABC as a Public Service Entity These national objectives therefore underpin the values and principles that define the SABC’s role as a public service media entity, that is: The SABC celebrates South Africa’s national identity and culture, and provides its citizens with the information they need to participate in building our democracy 2.2.3.4 Diversity and Inclusivity 2.2.2.1 to play a part in healing divisions of the past; 2.2.2.2 to promote respect for democratic values and human rights; 2.2.2.3 to provide information that allows citizens to exercise their rights; and 2.2.2.4 to reflect the rich diversity of a united South Africa. The values articulated in the Constitution, including national development, unity, diversity, non-racialism, non-sexism, democracy and human dignity, represent those things that are commonly considered by South Africans to be crucial. They bridge political, class, racial and gender divides, and anchor the diverse people of South Africa as a nation. For the SABC, these values must form the foundation of its editorial policies. 2.2.3 Core SABC Editorial Values Among the core editorial values for the SABC are: The SABC reflects South Africa’s diverse thoughts, languages, cultures, provinces and people in its programmes. 2.2.3.5 Human Dignity The SABC respects the inherent dignity of all South Africans, reflects them in all their diversity, and does not use language or images that convey stereotypical or prejudiced notions of South Africa’s races, cultures and sexes. 2.2.3.6 Accountability In discharging their editorial responsibilities, SABC management and staff are accountable to the South African citizens and the SABC Board. The Corporation’s Board is charged with ensuring that the SABC complies with the Charter and delivers on its public interest obligation. 2.2.3.1 Equality 2.2.3.7 Transparency The SABC provides relevant and useful content for everyone, in all official languages, and promotes universal access to its services. The SABC commits to treat South Africans equally, both as news subjects, sources of content and consumers of content. The SABC ensures that the principles of honesty, openness and transparency govern all editorial decisions and every aspect of the public broadcaster’s relationships with the shareholder, stakeholders, suppliers and the public. 2.2.3.2 Editorial Independence The SABC is governed by the Charter of the Corporation, which enshrines the journalistic, creative, programming and publishing independence of the staff of the corporation, and the constitutionally protected right to freedom of expression. In this regard, SABC journalists, its editorial and programming staff, enjoy the prerogative The core values referred to above are foundational to the SABC Editorial Code which informs all content production, processing and dissemination across radio, digital and television platforms. The Editorial Code was first approved by the SABC Board in 1993 and has since evolved to incorporate current developments in the broadcasting and publishing environments, and changes in the technological environment and the law. 4 3. The The Editorial Code Editorial Code The Editorial Code affirms commitment to the principle of editorial independence as it relates to SABC content. It enjoins the employees of the public broadcasting service to: a. report, contextualise, and present news and current affairs honestly by striving to disclose all the essential facts, and by not suppressing relevant, available facts, or distorting through misrepresentation or improper emphasis; b. understand that if South Africa is to build an informed nation and a strong democracy, its citizens must have access to relevant, credible, and timely information of the best quality; c. commission, produce, broadcast and publish content in a variety of genres and formats, and ensure that the SABC’s core values are upheld in commissioning, acquisition and production of programmes; d. be mindful of the danger of furthering discrimination, and avoid promoting discrimination through the SABC’s content offerings on the grounds of gender, race, language, culture, political persuasion, class, sexual orientation, religious belief, marital status, or disability; e. not allow commercial, political or personal considerations and prejudices to influence editorial decisions. The SABC is expected to provide information and as part of this duty should evaluate, analyse and critically appraise government policies and programme; f. consciously and vigilantly exercise editorial independence in executing decisions in all its content, taking into account that the SABC is not the mouthpiece of the government of the day or a state broadcaster, but covers the government and its programmes in the interest of the South African public; g. be free from obligation to any interest group and to prioritise its public interest obligation; h. respect individuals’ legitimate right to privacy, and avoid intrusion into private lives, grief and distress, unless it is justified by overriding considerations of public interest; i. be circumspect and sensitive in broadcasting and publishing any form of brutality, violence and human catastrophes; j. always seek to achieve balance by presenting a diversity of views in all content that requires impartiality. While fairness may not always be achieved in a single programme or content offering, it should be done within reasonable time and be guided by news value and editorial merit in reaching editorial judgements. Fairness does not require editorial staff to be unquestioning, nor require the SABC to give every side of an issue the same amount of time; k. be enterprising in perceiving, pursuing and presenting issues that affect individuals and society, in the quest to fulfil the public’s right to know; l. not accept gifts, favours, free travel, or other special treatment or privileges that could compromise the integrity of the public broadcasting service; m. disclose personal identity and that of the SABC before obtaining any information intended for programming. As a general obligation, all forms journalism should be conducted transparently. Discreet and covert methods may be used only with due regard to their legality, considerations such as fairness and invasion of privacy, and whether the information being sought is so significant and in the public interest that it warrants public disclosure but cannot be obtained by other means; n. resolutely uphold the principle of journalistic freedom and treat protection of sources as an important part of this principle. In the event that protection of a source becomes a legal matter, court orders cannot be disobeyed however, the SABC shall provide legal service to argue for protection of the source; o. correct any inaccuracies and misrepresentation in content timeously; p. provide opportunities for open dialogue with audiences across all SABC’s broadcasting and publishing platforms; q. tell stories from a South African perspective and deal with issues that are important to the public, including local, continental and global matters, and giving these proper context reflecting all complexities; r. support and preserve South African culture by providing content that is observably and uniquely South African, that encourages sharing of The Editorial Code 5 editorial independence of the newsroom, and editorial integrity of SABC News. While final editorial responsibility rests with the Group Executive of News and Current Affairs, with no upward referral of editorial decisions to the GCEO, the Group Executive of News and Current Affairs is still accountable to the GCEO for the overall performance of the news division. experiences, that nurtures a national identity and promotes nation building; s. be a truly independent public service media entity, showcasing South African life in a holistic manner; and t. provide a fully diverse content bouquet catering to a variety of tastes, and reflecting the colourful make-up of South African life including languages, cultures and geographical considerations. 3.1 Editorial Responsibility and Upward Referral 3.1.1 The scope of the public service mandate means that the SABC has to provide consistent, relevant, useful and high-quality content, including information and analysis. To strengthen and deepen public trust, SABC editorial staff should maintain the highest editorial and professional standards. Consistently, the SABC requires its editorial staff to understand that with the legislated and constitutional protection of the Corporation’s independence comes the responsibility to serve the public with the highest standards of excellence and integrity. 3.1.2 Accordingly, the onus is on individual Producers, Executive Producers, Editors and Commissioning editors to ensure that they understand and uphold the provisions of the the Act, including the Charter of the SABC, the Editorial Code, the BCCSA Code of Conduct for Broadcasters as outlined by the Broadcasting Complaints Commission of South Africa (BCCSA), the ICASA, and the Press Council of South Africa (PCCSA) Code of Ethics and Conduct, known as the Press Code. As a rule, and as a matter of policy, the authority for editorial decisions is vested in the editorial staff with the Group Executive of News and Current Affairs designated as the Editor-inChief of all SABC News services and platforms. 3.1.3 Subject to standard management and editorial controls, Executive Producers, Editors and Commissioning Editors are responsible for the production of content and editorial control. Should any difficulty arise during the production or publishing of content, or the producer or editor be unsure of anything, they should consult their supervisor for guidance. This process of voluntary upward referral could extend as far as the Group Executive of News and Current Affairs in his/her capacity as Editorin-Chief. The Group Chief Executive Officer (GCEO) has delegated responsibility, and holds the Group Executive of News and Current Affairs accountable for the performance of all news-related content on all news platforms, the 3.1.4 The SABC views upward referral as a mutually empowering, nurturing and developmental approach for all the staff involved. It is not intended to shift editorial decision-making upwards; but intended, when required, to underpin collective decision-making and shared editorial responsibility, especially when staff are faced with difficult decisions, and to underscore the interdependence between SABC’s management and that of its editorial staff. Upward referral is not intended to disallow production, broadcasting and publishing of controversial and compelling content; it is intended to assist in maintaining the highest ethical and editorial standards. 3.1.5 When used effectively, upward referral should be a seamless and flexible process. The earlier it is activated, the better, as this allows alternatives to be considered at the outset, instead of later, when few options are open. It is an approach that is taken by the world’s premier public service media. It assumes that editorial staff are familiar with the functions, duties and values of the public news service, and are in the best position to make editorial decisions. The practice of upward referral gives journalists and other editorial staff an ideal mechanism for consultation, first with peers, and then with senior management, before taking decisions. 3.1.6 Even when specific editorial advice is not asked for, programmes or news items that are controversial, or likely to have an extraordinary impact, or where significant ethical dilemmas warrant more inclusive consideration, should be reported in advance to the Editor-inChief. Should an Executive Producer, Editor or Commissioning Editor not refer an issue upward to their immediate supervisor, they would be held accountable for the editorial decision made. 3.1.7 Editorial staff should seek advice from the Legal Department on any matter that may have legal implications for the SABC. In addition, Legal Guidelines for editorial staff are available from the Legal Department and it is incumbent 6 upon all staff to familiarise themselves with its provisions. However, the final decision on whether to broadcast and publish, and in what form, lies with the editorial staff. The aim is to safeguard the independence of editorial process, and maintain clear responsibility for the decision to broadcast. 3.1.8 Independent content produced for the SABC is subject to the same rigorous standards as in-house productions, and has to comply with SABC editorial policies, as final responsibility for the content lies with the SABC. In this regard, all contracts with independent producers and other content providers must include the obligation to conform to all the appropriate sections of the SABC Editorial Policies. The point of referral for independent producers is the appropriate SABC Executive Producer, Editor or Commissioning editor. 3.1.9 Through the News and Editorial Subcommittee, the SABC Board shall exercise oversight to: a. protect the public broadcaster’s editorial and programming independence as set out in the Editorial Policies; and b. ensure accountability for the compliance and adherence with these Editorial Policies, taking into account that management retains operational responsibility for the enforcement of the policies across the Corporation. 3.2 Mandatory Referral As a rule, matters of sensitive and controversial nature including the following, must be referred to the relevant Editor or line management: 3.2.1 An instance in which it becomes necessary and is deemed to be in the public interest to gather information to which the public normally does not have access; 3.2.2 Interviews with criminals and people wanted by police; 3.2.3 Proposals to grant anonymity to people trying to evade the law; 3.2.4 Broadcasting or publishing of any recording made originally for other legal purposes, such as recordings of the proceedings at a meeting; 3.2.5 Disclosure of the details of a serious crime that were obtained surreptitiously or unofficially; 3.2.6 Requests from external parties to view, listen to, or obtain recorded material that has not been The Editorial Code broadcast or published; 3.2.7 Conducting interviews with prisoners for broadcast without the permission of prison Authorities; 3.2.8 Showing or featuring people in a live transmission for entertainment purposes using hidden cameras; and 3.2.9 Featuring a real person in a drama where their permission or that of their surviving relatives has not been secured. PROGRAMMING THAT TALKS TO ME 8 Programming 4. Policy on Programming and Publishing Preamble By virtue of its mandate, the SABC accounts to the South African public in providing high-quality, credible, relevant and diverse content offerings guided by: a. b. c. d. e. f. g. The SABC Charter; The SABC’s Core Editorial Values; The SABC’s Editorial Code; The BCCSA Code; The Press Code; ICASA Regulations; and ICASA Licence Conditions as set out in the individual licences for respective radio and television services. In prioritising the need to fulfil its public interest obligation, it is imperative for all SABC content productions, programing and publishing services to create an environment that respects freedom of expression as enshrined in the country’s Constitution, and that encourages producers to explore all facets of South African life without interference and adhering to the highest ethical standards. 4.1 Content Approach 4.1.1 Guiding Principles The SABC’s approach to its content offerings is guided by the following principles: 4.1.1.1 The premise of the SABC’s mandate is to deliver credible content aimed at informing, educating and entertaining its audiences, and the public in general. In exercising its journalistic creativity and to safeguard its reputation, the SABC has to adhere to the highest standards of independence, impartiality and editorial integrity. 4.1.1.2 In its obligation to educate, inform and entertain, the SABC must, without fail, always act in the public interest in conducting its business, content offerings, and in executing editorial decisions. While public interest is, expectedly, viewed as a fluid concept, considerations include freedom of expression; being ethical, providing content that enables people to make informed decisions on matters of public importance and their private lives; exposing criminal activities, damaging social behaviour, corruption, injustice, significant negligence and incompetence without hindrance. 4.1.1.3 All content offerings must be informed by the SABC’s core editorial values of equality, plurality of views, nation building, diversity, inclusivity, human dignity, accountability and transparency. These are applicable to the entire value chain, that is, commissioning of content, acquisition of content from agencies and production houses and in-house productions, scheduling and publishing of content 4.1.1.4 Viewed collectively, all content services must aim to meet the needs of all of the SABC’s audience segments. This extends to young and old, children in particular, urban and rural in all the provinces. While it may not always be possible to achieve full coverage of the country as determined by various constraints, concerted effort must be made to offer a wide range of information, educational and entertainment content, in different genres and formats, that appeals to a variety of interests and preferences 4.1.1.5 In delivering content of highest editorial standard across all services and genres, the SABC has to uphold its editorial independence and promote freedom of expression in providing factual content, as well as accurate, impartial and ethical news and current affairs services. 4.1.1.6 While freedom of expression enables the sharing of information and ideas without state, commercial or political interference, and encourages critical expression and engagement, it also carries responsibilities and is subject to legal restrictions and limits. In exercising freedom of expression, the SABC must also offer appropriate protection to vulnerable groups, and avoid causing unwarranted insensitivity and discomfort. 4.1.1.7 The SABC has a specific obligation towards coverage and reflection of children and young people in its news and general content. It must determinedly ensure that the best interest of the child is respected, including ensuring that their rights are protected and their voices Programming are heard, taking into account the evolving capacity of the child. Necessary care and ethical considerations must be taken when they are featured in content, to protect their dignity as well as their physical and emotional welfare. 4.1.1.8 Through its content, the public service media entity is obligated to encourage the development of South African expression and showcase the country’s talent. 4.1.1.9 Given South Africa’s history, the SABC has the responsibility to represent and reflect fully the story of its people, communities, and the nation within its local, regional and global context, fairly and diversely The SABC’s approach to its content offerings is further expanded in the Policy on Local Content and the Language Policy. It is also complemented by policies for specific genres including news and current affairs, educational and religious content. 4.1.2 Audience Engagement in Programming and Publishing 4.1.2.1 Phone-ins, discussion or debates and online engagements are an accepted and important means of audience participation, as they enable the public to participate in the national discourse or comment on matters of national and personal interest. However, the hosts or moderators are expected to take special care to uphold the SABC’s editorial principles of impartiality and independence, and to ensure that diverse views are accommodated across platforms. 4.1.2.2 Hosts or moderators should steer callers and guests away from making comments that may be against the law, SABC policies the BCCSA and Press Codes, and reprimand or contradict them tactfully, when necessary. It is important to ensure, as far as possible, that audience engagement opportunities do not become a focus or platform for organised pressure groups and irresponsible individuals. A short pre-interview by a “screener” should be used for these purposes. A record is to be kept of the names of all the speakers and their contact information, and retained for at least 30 days. 4.1.2.3 When written comments are received, hosts or moderators should be vigilant and acknowledge them. The prescribed minimum requirement for subtitling, audio captioning, audio description and closed captioning is over a period of 10 years, for each tier of broadcasting. Cases of factual inaccuracies or violations of regulations and the law or SABC policies must be pointed out. 4.1.2.4 Since phone-ins, discussions and online audience engagements are not scientific ways of surveying public opinion on any matter, there should be no suggestion, explicit or implicit, 9 that the views from such reflect wider public opinion. More on this subject is set out in the Policy on News and Editorial Content. 4.1.3 Taste, Decency, Hate Speech and Graphic Content Issues of taste, decency, hate speech and graphic material in content offerings are often regarded as controversial in that they involve judgements based on a variety of influences including personal opinion, religious, political and cultural persuasions, as well other global values systems. The notion of public morality is relative, culturally fluid, difficult to define with any sense of precision, and bears no objective criterion. In addition, the freedom of expression provided for in the Constitution, protects even unpopular and sometimes speech that may be deemed offensive by others. However, consistent with both the BCCSA and Press Code, due care and responsibility must be exercised in reporting, programming and publishing content that contains gratuitous violence, brutality, explicit content, violent crime and all forms of discrimination. Instead of placing a complete ban on material that might offend certain individuals or groups, the BCCSA Codes provide directives to: 4.1.3.1 Give adequate warning beforehand when producers and publishers believe the material may be deemed offensive or upset some of the viewers/listeners; 4.1.3.2 Be sensitive and circumspect in their scheduling of such material; and 4.1.3.3 Make sure material that is unsuitable for children is not broadcast outside the watershed period (from 21:00 to 05:00). With regard to the treatment of discrimination and hate speech as well as violence and graphic content on digital platforms, the Press Code obliges the media to: 4.1.3.4 avoid discriminatory or denigrating references to people’s race, gender, sex, pregnancy, marital status, ethnic or social origin, colour, sexual orientation, age, disability, religion, conscience, belief, culture, language and birth or other status, and not refer to such status in a prejudicial or pejorative context not unless it is strictly relevant to the matter being reported, and is in the public interest; 4.1.3.5 balance the right and duty to report and comment on all matters of legitimate public interest against the obligation not to publish material that amounts to propaganda for war, incitement of imminent violence or hate speech and that constitutes incitement to cause harm; 4.1.3.6 exercise due care and responsibility when presenting brutality, violence and suffering 3.1.3.7 not sanction, promote or glamorise violence or unlawful conduct; and 10 4.1.3.8 avoid content which depicts violent crime or other violence or explicit sex, unless the public interest overrides, in which case a prominently displayed warning must indicate that such content is graphic and inappropriate for certain audiences such as children. Although the SABC makes every effort to minimise what audiences might find distasteful or tasteless, it has to deal frankly with controversial topics and cannot avoid tackling issues because of the risk of offending certain people or section of the population. The SABC also broadcasts and publishes content that some might oppose, or find offensive, but that has creative or social merit. Such content is aired and published: 4.1.3.9 with due consideration of audience sensibilities; 4.1.3.10 with audience advisories; and 4.1.3.11 at appropriate times. Careful scheduling and appropriate warning or advice allows our public to make informed choices about what they want to see and hear. This practice does not detract from the SABC’s editorial responsibilities in any way, but entrenches the culture of respect for freedom of expression, and the right to receive and impart information. 4.1.4 Audience Advisories The BCCSA Code is predicated on the notion that audiences should be given the freedom and responsibility to choose what they wish to see, hear or read, but that they can take this responsibility only when they are adequately informed about potentially problematic material in advance. The Codes requires broadcasters to give warnings that are clear to the audiences. They include age indicators, symbols for content such as graphic or excessive violence, explicit sexual conduct, nudity and bad language, including profanity. Respecting the right to choose also means not allowing material that viewers and listeners might find threatening or shocking to intrude unexpectedly. Alerting the audience is likely to lessen the negative impact of violent or distressing scenes. In line with this requirement, The SABC has established the following procedures for acceptance and screening of content for suitability and to meet the highest editorial standards: 4.1.4.1 Each television channel employs staff dedicated to viewing and classifying all programmes to be broadcast by the channel, using a set of Programming guidelines for treating potentially controversial material. If the designated staff is in doubt about a classification, the matter is referred to the supervisor of the programme acceptance unit. The supervisor may take a decision, or refer the material for review to the management of the channel and/or Broadcast Compliance management. In certain cases, material may be referred to the Legal Department for advice. 4.1.4.2 Classification includes deciding on the appropriate age indicator and warnings to be displayed on the programme, and the most suitable time-slot for the broadcast. 4.1.4.3 The age-rating parameters used by the SABC television channels are PG (parental guidance), PG10, 13, 16 and 18. 4.1.4.4 Standardised warning symbols are displayed on any programme containing material that could be disturbing or offensive: V (violence), S (sex), N (nudity), L (bad language, including profanity) and P (prejudice). 4.1.4.5 A PG advisory may not be used on its own but must be accompanied by a relevant age restriction as well, such as PG10 or PG13. 4.1.4.6 Although profanity and explicit language is a natural component of regular discourse, viewers may justifiably find it offensive. The SABC therefore, must to apply the “L” symbol rigorously or in the case of news coverage have a permanent textual warning on the screen where profanity or explicit language is concerned or anticipated, to minimise distress to those audiences who may be offended. 4.1.4.7 The age rating and warning symbols are displayed for 60 seconds at the start of the programme, and for 30 seconds after each advertising break. These times could be increased for extremely controversial material. 4.1.4.8 Cautionary announcements are made verbally and/or visually at the start of programmes that could be exceptionally disturbing to certain viewers. 4.1.4.9 On-screen promotional material and line-ups display the age indicator and warning symbols for each programme, for the full duration of the promo. 4.1.4.10 The SABC’s policy on consumer advice requires all music videos and fillers to be approved in advance, and scheduled in specific time-slots in accordance with the watershed period. 4.1.4.11 Since radio is a more pervasive medium than television, as much care should be taken to respect the audience’s rights as for television. The same principles of advisories apply to sensitive material broadcast over the radio, or anything that may offend or cause discomfort to certain listeners, or is unsuitable for children. 4.1.4.12 Across SABC platforms, where an item is published on the basis of limited information, Programming this shall be stated explicitly as such, and the content should be supplemented once new information becomes available. 4.1.4.13 All platforms shall make amends for presenting information or comment that is found to be inaccurate, by communicating promptly and with proportionate prominence so as to readily attract attention, a retraction, correction or explanation. 4.1.4.14 The Press Code provides a clear directive that, when digital content has been amended for factual accuracy it must be indicated as such. In the event of an apology or retraction, the original item may remain, but the publisher must indicate in a prominent manner that it has led to an apology or retraction, and should link to both the apology/retraction and the initial item. 4.1.4.15 No person shall be entitled to have content removed from digital platforms which falls short of being defamatory, but is alleged by such person to be embarrassing. Provided that content may be removed from digital platforms if content violates the rights of the child by, for example, identifying the child or children in non-compliance with these policies. 4.1.5 Screening of Films Where a Film and Publications Board (FPB) classification for a film exists in terms of the Film and Publications Act No. 65 of 1996, as amended, such classification is the minimum advisory to be used for the broadcast of the film: 4.1.5.1 “A”: suitable for all ages. These films do not contain anything that is considered harmful or disturbing to even very young children. 4.1.5.2 “PG”: Parental Guidance – alerts parents to films that contain scenes, or deal with themes, that might confuse or upset certain children if they were to watch them alone. Parents are advised to monitor their children’s viewing. 4.1.5.3 V (violence), S (sex), N (nudity), L (bad language, including profanity), SV (sexual violence), D (drugs/substance abuse) and P (prejudice). 4.1.5.4 “10”, “13”, “16” or “18”: films that are unsuitable for children under the stipulated age. This is a legally restrictive classification. No version of a film that has been refused FPB certification (which carries an XX classification) may be broadcast at any time under any circumstances. 4.2 Digital Content and Publishing In line with the public service media entity’s mission to provide “content that is accessible by all”, the SABC’s digital offerings should include low bandwidth formats; ensure that online and social media content is usable 11 on data zero-rated platforms; and utilise low bandwidth multimedia distribution platforms where possible to ensure that its online content is universally accessible. The SABC’s digital platforms are: a. Integral to the SABC’s public and commercial content offerings; b. Crucial in extending the public service mandate to a broader audience; and c. Essential to serve future audiences reliant on digital and on-demand public service content.   4.2.1 Production and Publication of Digital Content The SABC’s digital content production and publication platforms include: 4.2.1.1 Websites; 4.2.1.2 Apps (web and mobile applications); 4.2.1.3 Social media (Twitter, Facebook, Instagram); 4.2.1.4 Messaging services (WhatsApp, Facebook Messenger, Snapchat); 4.2.1.5 Online video, including live streaming (using services like YouTube, Facebook Live, Periscope, own services); 4.2.1.6 Online audio (podcasts, live streaming); and 4.2.1.7 Other third party platforms for online content production and curation (Storify, Snacktools, infographic tools and others). The rapid evolution of online platforms and tools require operational flexibility to adapt and adjust to use the best platforms for the right purpose at the right time. Therefore, these platforms or their usage may change frequently. The introduction of online services, including new social media accounts, new tools and new platforms should be subject to set standards and procedures to ensure good governance and uniformity in digital presence, managed and guided by the digital units in the specific SABC divisions. In the process to test and approve new services, digital units should consider the public adoption of such new services, maintenance of previous services, appropriate publication workflows, internal training support and adherence to SABC corporate visual identity standards. In line with its mandate, and as the primary digital source of public service content, the SABC endeavours to: 4.2.1.8 Provide independent digital content services and create digital-only content brands to serve existing and new audiences, utilising content specifically produced for digital platforms, as well as curating and repackaging of audio and video content. These initiatives are typically driven by digital content production units within the various SABC divisions; 4.2.1.9 Produce digital content, in the form of social media, podcasts, audio or video live streaming 12 and other related material, in support of existing broadcast products, by the teams responsible for those broadcast services jointly with digital content units. This is aimed at serving existing radio and TV audiences and extend the reach of broadcast products to new audiences; 4.2.1.10 Serve audiences outside the reach of television and radio services, such as those outside the borders of the country; those who prefer ondemand digital content over linear viewing and listening; and audiences whose media consumption patterns show a move away from linear programming and a preference for digital content; 4.2.1.11 Utilise digital media platforms for public engagement and participation in all the SABC’s content initiatives; 4.2.1.12 Ensure that digital content production is part of the editorial planning process, integrated into production workflows and subject to the same editorial approval processes as broadcast material; 4.2.1.13 Emphasise an integrated collaborative approach, and place a particular obligation on broadcast services to provide consistent and comprehensive online updates in the form of social media and online video and audio in the languages in which they broadcast; and for provincial bureaux to provide similar online content for their geographical areas of responsibility; 4.2.1.14 in the same way live and recorded programming is monitored on radio and television, ensure that editorial management directs and monitors digital content output, provides editorial guidance, identifies problems and oversees swift corrections when needed, as required in the Press Code. 4.2.2 Programming 4.2.2.2 be transparent with the audiences about the verification status of UGC; 4.2.2.3 be circumspect to the emotional state and safety of contributors; 4.2.2.4 consider the risk inherent in asking a contributor to produce and deliver UGC, including whether it incentivises others to take unnecessary risks; 4.2.2.5 consider technical measures to ensure anonymity of sources when required; 4.2.2.6 seek informed consent for the use of UGC through direct communication with the individual who created it; 4.2.2.7 be transparent about how content will be used and distributed to other platforms; 4.2.2.8 give due credit to the owner of the content providing that consideration has been given to potential consequences, including their physical, mental and reputational well-being; 4.2.2.9 to inform and equip journalists to confront the dangers of engaging with sources through social media networks and the digital footprint they leave behind; 4.2.2.10 support and assist staff and journalists who are confronted with graphic or otherwise disturbing content; and 4.2.2.11 maintain an organisational culture that enables journalists to seek help or speak out when they need to protect their mental health. 4.2.3 Digital Media Guidelines The guidelines are meant to regulate conduct and management of institutional and personal digital media accounts. They are to be read with the full Digital Media Policy of the SABC, and observed at all material times. These guidelines and requirements as set out in the Editorial Policies will prevail, should there be any conflict between the Editorial Policies and the full Digital Media Policy. User-Generated Content (UGC) Industry standards and practice oblige the SABC to formulate a policy to guide its employees in terms of utilising user-generated digital content. In a far as news gathering and publishing is concerned, the Social Newsgathering Ethics Code, originally compiled on 7 April 2016 by the US based Online News Association, and subsequently endorsed by many major news organisations around the world as a set of best practices for the gathering and use by the media of content created by members of the public, is the reference point. However, the Social Newsgathering Ethics Code does allow for general application in the way UGC is managed. In line with the South African Press Code and the Social News Gathering Ethics Code, the SABC should: 4.2.2.1 verify the authenticity of UGC before publishing or distributing it, holding it to standards that are equal or equivalent to those maintained for content acquired through other means; 4.2.3.1 An individual’s freedom of expression on social media must be balanced with the rights of others to privacy and dignity, as well as the SABC’s right to engage in both commercial activities and deliver on its mandate as public broadcaster and operate in the public interest. 4.2.3.2 The SABC’s digital media users are personally responsible for what they publish online and they should take considerable care in what they publish digitally. Sound judgment and common sense should guide their online activities. When in doubt or uncomfortable, posting anything on digital platforms should be avoided. 4.2.3.3 SABC users of online media platforms should be mindful of the global and permanent nature of online communications. Information that would not ordinarily be revealed to others should not be divulged online either. 4.2.3.4 The rights of others, as outlined in the Constitution of South Africa, are to be respected. Programming This includes the rights of both individuals and organisations. 4.2.3.5 Opinions should be expressed without resorting to personal attacks, gender and ethnic slurs, obscenity, social insensitivity, discrimination, or harassment. 4.2.3.6 SABC users need to be mindful of the constitutional rights of others to privacy and dignity. 4.2.3.7 The SABC does not pay for followers, site visitors, or online friends – the number of followers or friends should be a true reflection of the account’s influence and reach. Employees are expected to adhere to this principle in their own social media activities as well. 4.2.3.8 Content on digital media is subject to defamation law. SABC employees should be mindful of linking to material on third party sites that contain defamatory material. They should not forward or repost information of defamatory nature as they can be held legally liable along with the originator of the content. 4.2.3.9 The SABC’s digital media users should be ready to defend any views they express online. They should use discretion, and rather err on the side of caution and avoid crass or derogatory language. 4.2.3.10 The SABC does not broadcast gratuitous violence, and this extends to digital media. SABC digital media users should take care not to reflect anything of this kind in their online activities. 4.2.3.11 SABC users should guard against linking to or commenting on images or videos of violence or violent acts. These can reflect on personal profiles and could expose account owners to legal action. Incitement of violence or hatred is a crime, and this applies to any such on digital media as much as anywhere else. 4.2.3.12 The SABC does not broadcast explicit sex or pornography and its employees are to adhere to this in their online activities as well, be they professional or personal. Online content of a sexual nature should be used, linked to, or commented on with extreme circumspection. 4.2.4 Guidelines for Official SABC Digital Media Accounts 4.2.4.1 These guidelines underpin the importance of the SABC as a trusted and credible news source, especially important in the digital sphere where misinformation and disinformation are rife and seek to undermine democracy. The role and importance of the SABC in combatting disinformation is therefore critical. 4.2.4.2 SABC digital media accounts are official SABC platforms and services, and are as important and influential as other more traditional platforms. The same forethought, care, and planning need 13 to be applied in using these platforms as with any other SABC communication tools. 4.2.4.3 Knowledge should be shared in a constructive manner, being sure to separate opinion from fact in what is published online. 4.2.4.4 When posting content such as video from third parties on official SABC social media platforms, individuals and account administrators need to make sure that are authorised to do so and that the SABC has digital rights for the relevant content. When in doubt, clarity must be sought from the relevant line manager, the producer of the content, and/or the SABC’s Legal department. 4.2.4.5 UGC, such as online comments solicited through an official SABC social media account, needs to be treated with goodwill and circumspection. Employees may not claim to own the intellectual property or copyright to any UGC that is not their own. Official digital accounts of the SABC need to set out in their terms and conditions or disclaimers that users grant the SABC permission to use their content on any official SABC platform, but also state clearly that the SABC will not claim ownership of such content if it has no such mandate or permission. 4.2.4.6 Just as the SABC distinguishes between a station/ channel’s commercial objectives and news mandate in general, the same must apply to social media. Sponsored links should be clearly labelled as such and not disguised as journalistic or editorial content. 4.2.4.7 All the SABC’s official digital media accounts must use imaging and branding that is consistent with that of the SABC’s various approved brands, symbols and corporate identity. 4.2.4.8 Great care, sensitivity and caution needs to be exercised when interacting with children on social media. While users’ ages are not always stated, where it is known or suspected that a user is a child they may not be used as an information source without the consent of their parent or guardian, and taking into account the evolving capacity of the child, with their informed consent as well. Their identity may also not be made known without the specific consent of the child and their parent or guardian. 4.2.4.9 When in doubt about any online media account or activity, the standard editorial upward referral processes should be followed. 4.2.5 Guidelines for Personal Digital Media Accounts 4.2.5.1 Any use of digital media platforms using work resources, including work time and facilities, is open to the organisation for scrutiny and remedial action, should this be required. 4.2.5.2 Employees must respect the intellectual property and copyright of the SABC. Individuals are not 14 allowed to post SABC content, be it video, audio, stills, or copy, on their own social media platforms without giving due credit to the SABC. They may also not create the impression that they own the intellectual property rights or copyright of any SABC content. 4.2.5.3 No payments will be made by the SABC for posts, comments, or reviews, and incentives for further distribution or reproduction (re-tweets, for example) are disallowed. 4.2.5.4 Any digital media writing or posting by an SABC employee that is paid for or incentivised by anyone other than the SABC constitutes commercial work or exposure and needs to be declared and approved through the standard SABC processes for this. 4.2.5.5 As per the SABC’s Conflict of Interest Policy, an employee or relevant stakeholder’s online media activity may not constitute a conflict of interest with the SABC’s mandate and business imperatives, be that conflict direct or indirect. This includes, but is not limited to: selfdealing, advocacy activities, accepting benefits, influence peddling, using the SABC’s property and/or resources for personal advantage, using confidential information, obtaining outside employment or moonlighting, or taking advantage in post-employment. 4.3 Scheduling and the Watershed Period Section 7 of the BCCSA Code specifies a watershed period for television broadcasters. The requirements are specified as follows: 4.3.1 Programming on television which contains scenes of explicit violence, and/ or sexual conduct and/ or nudity and or grossly offensive language intended for adult audiences must not be broadcast before the watershed period. 4.3.2 Promotional material and music videos which contain scenes of explicit violence and/ or explicit threatening violence and/ or sexual conduct and / or the fondling or touching of breasts and / or genitalia or the anus and/ or nudity and/ or offensive language for adult audiences must not be broadcast before the watershed. 4.3.3 Promotional material for adult programmes may be broadcast outside the watershed period, provided it does not contain scenes of violence, sexually explicit conduct, nudity and/ or bad language. On such promotional material the age restriction and warning symbols that apply to the programme are to be displayed throughout. 4.3.4 The watershed period extends from 21:00 to 05:00. 4.3.5 Some programmes broadcast outside the watershed period may not be suitable for very young children. Licensees must provide Programming sufficient information, in terms of regular scheduling patterns or audience advisories, to assist parents and defacto or legal guardians to make appropriate viewing choices. 4.3.6 Television broadcasting licensees may, with the advance of the watershed period, progressively broadcast more adult material. 4.3.7 Broadcasting service licensees must be particularly sensitive to the likelihood that programmes which commence during the watershed period and which run beyond it may then be viewed by children. 4.3.8 During the watershed period, progressively less suitable (more adult) material may be shown. For instance, a programme might be acceptable at 23:00 that would not be suitable at 21:00 4.3.9 Broadcasters should be alert to the likelihood of children watching programmes that begin before the watershed period and run into it 4.3.10 Given the probability of older children being in the audience during the watershed period, broadcasters are to give consumer advice that would allow parents to take informed decisions on the suitability of programmes for their family. 4.3.11 It is self-evident that if material is not suitable for viewing by children, it should not be broadcast when large numbers of them may be expected to be watching television. Outside the watershed period, then, nothing should be shown that is inappropriate for children, or for family viewing. After 21:00 parents are expected to share the responsibility with the programming entity for what their children are permitted to see. 4.3.12 Regular broadcasting of programmes with age restrictions of 13 or over between 17:00 and 20:00 is discouraged. 4.3.13 The SABC’s programme scheduling should also take account of public holidays, religious festivals/holidays, events of cultural or international significance, and country-wide school holidays, that is, when holidays in all or most of the provinces coincide. 4.3.14 In general, the SABC’s answer to the potential clash of interests between controversial programming and some viewers’ concerns requires due care and sensitive management in scheduling. In its role as a public service media entity, the SABC is expected to extend the range of experience of its viewers and listeners through its programmes. It needs to strike a careful balance between respect for fundamental rights, and audience sensitivities and expectations. Programmes that challenge accepted world views, and offer new experiences and opposing perspectives, are the hallmark of robustness in public service content. 4.3.15 Although the BCCSA Code does not specify a watershed period for radio, the SABC abides Programming by the dictum that stations do not broadcast material that is unsuitable for children at times when they are likely to form a large part of the audience. For instance, radio stations should be aware that children are likely to be listening to the radio while travelling to and from school. School holiday periods, when more children are likely to be listening to radio during daytime hours, also require special attention. 4.3.16 In terms of the freedom of expression provisions in the Constitution, it is impossible to prohibit “offensive” language on live radio programming. The BCCSA Code says that when transmitting material containing profanity, or other religiously insensitive material that is likely to offend a section of the audience, broadcasters should give appropriate warnings to allow audiences a choice. 4.3.17 The BCCSA free-to-air Code prescribes that bad language, including profanity and other religiously- sensitive material, should not be used in programmes that are specially designed for children. It also specifies that no excessively or grossly offensive language should be used before the watershed on broadcasts, or at times when large numbers of children may be expected to be in the audience. 4.3.18 Public media is an important source of information and culture, and could influence standards and values through its use of language. Therefore, the SABC needs to maintain high standards of integrity with regard to language usage, including but not limited to all official languages. Correct language use is one of the most frequent causes for complaints, particularly incorrect grammar, mispronunciation, negative stereotyping and profanity. Guidelines on language usage are contained in the section on Language Policy on Content. 4.4 Discrimination and Stereotypes The Press and BCCSA Codes do deal with stereotyping and discrimination albeit in general terms. Furthermore, ICASA encourages broadcasters to develop their own internal guidelines for dealing with these matters. Given South Africa’s past, and the role of public service media in healing divisions, it is imperative for the SABC not to broadcast programmes that promote discrimination or stereotyping on the grounds of race, national or ethnic origin, colour, religion, gender, sexual orientation, age, or disability. To this end, the SABC is committed to avoiding language, expressions and images that reinforce stereotyping, and offend communities or individuals. The SABC is further committed to reflecting diversity positively and undertakes to provide content that is devoid of stereotypical representations in respect 15 of persons with disabilities, gender, race and sexual orientation and any other South Africans who have often been marginalised, or represented in narrow and stereotypical terms. In this regard, the SABC’s policy seeks to: The SABC’s policy seeks to: a. treat every part of society with respect; b. not identify people solely by ethnic origin, and to mention race and /or ethnicity only where relevant and where it adds value to the content; c. avoid any unnecessary reference to disability, as it is often seen as insulting or implying deficiency, and not to use language that could add to such an impression: e.g. “deaf” or “hard of hearing” should be used, and “a person with disability” instead of “invalid” or “cripple” or “retarded”, similarly avoid “wheel-chair bound” and refer to wheel-chair users” instead; d. use non-sexist language so as to avoid giving offence, or creating the impression – through repetition - that certain activities are associated with only one sex, and also have due regard for the different and diverse gender and sexualities, and refer to people in the gender they choose to identify as, for example “he, she, they”; and e. avoid humour that is excessively exploitative, uncalled for, cruel, or designed to prejudice a person or group. These requirements are not intended to preclude provision of factual material, or views expressed in satirical or dramatic works, however, the context in which the language is used is pivotal. 4.4.1 People with Disabilities 4.4.1.1 The SABC recognises that persons with disabilities often feel marginalised, and that in its duty to the public it has to promote access by these audience segments to its services, and ensure that the representation of people with disabilities in its content offerings is fair. 4.4.1.2 The SABC therefore treats persons with disabilities respectfully in its services, and is committed to reflecting issues of disability in a way that does not perpetuate harmful and negative stereotypes direct as people with disabilities. 4.4.1.3 The SABC must commit to explore mechanisms for enhancing delivery of content to people with disabilities. Where possible, it must also strive to involve persons with disabilities in such initiatives. 4.4.2 Race 4.4.2.1 In the context of South Africa’s history, the SABC takes particular care when dealing with issues of racism, xenophobia, and in depicting race. In 16 this regard, it commits to representing issues of race in a way that does not perpetuate negative stereotypes, and that creates awareness of such stereotypes. To this end, unjustified racial identifiers are to be avoided, such as divulging race, ethnicity and/or nationality, unless there is a compelling reason to do so. 4.4.2.2 The public service media also undertake to raise awareness regarding racial discrimination by encouraging opening and robust debate and discussion of such issues. This goal translates into encouraging and promoting a non-racial approach and perspective to issues even among staff. Programming 4.4.3 Gender 4.4.4.3 sanctions, promotes or glamorises any aspect of violence against women; 4.4.4.4 depicts women as victims of violence unless the violence is integral to the subject of coverage; 4.4.4.5 perpetuates the link between women in a sexual context and women as victims of violence; 4.4.4.6 promotes or glamorises violence or unlawful conduct based on race, national or ethnic origin, colour, religion, gender, sexual orientation, age, or mental or physical disability; and 4.4.4.7 amounts to: a. propaganda for war; b. incitement of imminent violence; or c. the advocacy of hatred that is based on race, ethnicity, religion or gender and that constitutes incitement to cause harm. In line with other commitments raised in other sections of these policies, the SABC undertakes to ascertain that its content offerings do not: Public service media entities are reminded of the possible dangers of some people imitating violence, details of which they see, hear or read about. 4.4.3.1 promote violence against women; 4.4.3.2 degrade women and undermine their role and position in society; 4.4.3.3 promote sexism and gender inequality; and 4.4.3.4 reinforce gender oppression and stereotypes. Considering the above, section 3 and 4 of the BCCSA Free-To-Air Code and section 9 of Press Code however direct that the above mentioned prohibitions shall not apply to: Furthermore, the SABC is committed to: 4.4.3.5 reflecting and portraying women in their positive societal roles - as independent intellectual beings; as leaders, decision-makers, academics, agents for change; 4.4.3.6 simultaneously avoid representation of men in roles that bolster gender ascendancy and stereotypes; 4.4.3.7 consciously seek gender balance in content offerings, such as those requiring a range of opinions on issues of public importance; and 4.4.3.8 Having due regard to diverse genders and sexualities, and ensure members of the LGBTIAQ communities are fairly represented and not discriminated against. 4.4.4 Violence Section 3 of the BCCSA Free-To-Air Code and section 9 of the Press Code are consistent in their approach to the treatment of violence and its representation in content offerings. They direct the media to avoid content offerings or any material which, judged within context: 4.4.4.1 contains violence which does not play an integral role in developing the plot, character or theme of the material as a whole; 4.4.4.2 sanctions, promotes or glamorises violence or unlawful conduct; 4.4.7.8 a broadcast which judged within context, amounts to a bona fide scientific, documentary, dramatic, artistic, or religious broadcast; 4.4.7.9 a broadcast which amounts to a discussion, argument or opinion on a matter pertaining to religion, belief or conscience; or 4.4.7.10 a broadcast which amounts to a bonafide discussion, argument or opinion on a matter of public interest Violence manifests itself in many forms, and attitudes to it range from shock to disgust, passive acceptance and approval, depending on the context. The media’s portrayal of violence may influence how it is received and acted on in society, and it has been suggested that violence in media content offering may induce apathy, insensitivity, or aggression in certain individuals. Modern technology allows images of violence to be published to people who have little or no real contact with it in their daily life. The SABC therefore has a duty not to glamorise any type of violence, nor to promote it, and to depict it only when it could help to portray a story, evoke compassion, prompt help, or simply be an accurate representation of real events and is in the public interest to show it. In addition to provisions in the Press and BCCSA Codes, the SABC’s policy on violence is as follows: 4.4.7.11 To broadcast programmes or scenes containing images of violence if they are needed in order to portray legitimate information or context; Programming 17 4.4.7.12 To ensure that any broadcast of material containing scenes of violence, or violent behaviour, is justifiable in the context of the SABC’s functions and purpose; 4.4.7.13 To use an appropriate form of audience advisory to give advance notice when violence is to be shown; 4.4.7.14 To treat the subject of suicide, or attempted suicide, with circumspection, and not to give any detailed demonstration of the means of suicide; and where necessary refer to “attempt to take one’s life” rather than “committing suicide”. 4.4.7.15 To avoid portraying dangerous behaviour that children could easily imitate; and 4.4.7.16 To use scenes of violence or cruelty to animals prudently and with adequate warning, as viewers are disturbed by such material. 4.4.5.5 The content amounts to fair comment based on facts that are adequately referred to and that are true or substantially true; 4.4.5.6 The content amounts to a fair and accurate coverage of court proceedings, parliamentary proceedings or the proceedings of any quasijudicial tribunal or forum; 4.4.5.7 It was reasonable for the information to be communicated because it was prepared in accordance with acceptable principles of journalistic conduct and in the public interest; or 4.4.5.8 The content was or formed part of, an accurate and impartial account of a dispute to which the complainant was a party. The SABC’s aim is not to see how much violence will be tolerated, but how little is needed to achieve honest ends without undue dramatic or editorial compromise. Careful consideration guides the SABC in its interaction with people who are grieving or in distress. They are often in an intensely emotional state and may not be able to decide rationally about giving comment or interviews. In such cases, discretion should be used in filming or interviewing them. People in distress should be treated with dignity and compassion and any broadcasting or publishing of their displays of grief should be kept to a minimum where showing it is justified and in the public interest. Further guidelines on violence in news programmes are dealt with in the News, Current Affairs and Information Policy. 4.4.5 Privacy, Dignity and Reputation The Constitution protects fundamental human rights, and affords every South African the right to privacy and dignity. Related to this, the BCCSA and Press Codes require the media to exercise exceptional care and consideration in matters involving the private lives and private concerns of individuals. However, the right to privacy may be overridden by public interest. The SABC expects decisions of this kind to be taken with due consideration of all applicable guidelines, regulations and policies, and likely consequences of the action to be deliberated carefully. The following are guidelines applicable to matters of privacy, dignity and reputation: 4.4.5.1 The public has the right to receive information about public figures and public institutions, if this is in the public interest; 4.4.5.2 Invasion of privacy may be justified in order to disclose information that has a bearing on someone’s performance of public duties, or on any matter of public interest; and 4.4.5.3 Aspects of the private lives of public figures that are pertinent to their public duties must be distinguished from those that are not. While due care and consideration must be exercised in matters involving privacy, dignity and reputation of an individual, it should be overridden only if it is in the public interest and in the following circumstances: 4.4.5.4 The facts presented are true or substantially true; 4.4.6 Grief, Suffering and Distress The SABC is committed to: 4.4.6.1 respecting everyone’s right to privacy and dignity, and to treating grief-stricken people with sensitivity; 4.4.6.2 not identifying victims/survivors of rape, or of sexual violence in general, without their express and informed consent; and 4.4.6.3 not identifying or interviewing child victims of abuse or where children are accused of a crime, or where they are witnesses to a crime, unless exceptional circumstances indicate it to be demonstrably in the best interests of the child, and informed consent of the parent and or guardian, and where possible, the child concerned has been obtained. 4.4.7 HIV/AIDS - Medical Conditions With regard to treating content relating to HIV/AIDS, the SABC shall: 4.4.7.1 not disclose the HIV status or any medical condition of anyone without their express consent, unless it would be in the public interest to do so. Therefore, unless there are compelling public interest reasons, consent to disclosure should be obtained, and if possible should be obtained in writing (in the form of a waiver of the person’s right to privacy); 18 4.4.7.2 not disclose the HIV/AIDS status or any sensitive medical condition of a child without their consent, together with the consent of their legal guardian or similarly responsible adult, provided it is fully informed consent and that it is demonstrably in the best interests of the child and in the public interest; 4.4.7.3 adopt the principle that HIV/AIDS and other sensitive medical conditions should be destigmatised, and members of society should be educated to conduct their lives responsibly; and 4.4.7.4 encourage communities to embrace the people living with Aids and other sensitive medical conditions; to create empathy and understanding for them; not to ostracise them, but to accord them dignity as members of society. The guidelines on privacy and dignity are elaborated on further in the News, Current Affairs and Information Policy. Editorial staff should also consult the Legal Guidelines specific to editorial matters. 4.5 Children Section 6 of the BCCSA free-to-air Code and section 8 of the Press Code provide the following provisions regarding children as consumers and subjects of media content: 4.5.1 Media entities are reminded that children embrace a wide range of maturity and sophistication. In interpreting the BCCSA Code, a distinction should be made, if appropriate, between those approaching adulthood from a much younger, pre-teenage audience. 4.5.2 Media entities must not broadcast material which is harmful or disturbing to children at times when a large number of children are likely to be part of the audience. 4.5.3 Particular caution must be exercised, as provided below, in the depiction of violence in children’s content offerings. 4.5.4 In children’s content portrayed by real-life characters, violence - whether physical, verbal or emotional - may be portrayed only when it is essential to the development of a character and plot. 4.5.5 Animated content for children, although it is accepted as a stylised form of storytelling that could contain non-realistic violence, may not have violence as their central theme, nor invite dangerous imitation. 4.5.6 In producing children’s content, due care should be taken in dealing with themes that could threaten their sense of security, such as the portrayal of domestic conflict, death, crime, or drug abuse. Programming 4.5.7 Due care should be taken in dealing with themes that could invite imitation, such as the use of plastic bags and dangerous household products as playthings, use of matches, and other hazardous physical acts. 4.5.8 Children’s content may not contain realistic scenes of violence, or which create the impression that violence is the preferred or only method to resolve conflict between individuals. 4.5.9 Children’s content may not contain realistic scenes of violence that minimise or gloss over the effect of violent acts. Any realistic depiction of violence should portray, in human terms, the consequences for its victims and its perpetrators. 4.5.10 Children’s content may not contain frightening or otherwise excessive special effects that are not required by the story line. 4.5.11 In The spirit of Section 28(2) of the Bill of Rights, the media shall exercise exceptional care and consideration when reporting about children. If there is any chance that coverage might cause harm of any kind to a child, he or she shall not be interviewed, photographed or identified without the consent of a legal guardian or of a similarly responsible adult and the child (taking into consideration the evolving capacity of the child); and a public interest evident. The SABC offers a diverse range of content for children, from toddlers to adolescents for entertainment, education and information. The extensive range of material for young audiences is designed to reach different target groups at times best suited to their needs, age and level of maturity. The SABC takes special care to ensure that content offerings that children are likely to consume unsupervised would not cause alarm or distress, or incite aggressive behaviour. It is important to note that offering children enjoyable and enriching content is not to be confused with concealing the real world from them. Adults sometimes seek to exclude from television certain images and words, or coverage of certain events, in an effort to protect children. For some children, though, the world is already violent and dangerous, and it is important for the media to help them understand and deal with their own lives. It is also important that the SABC strives to ensure that children’s voices are heard on matters that impact them, bearing in mind that all such efforts must be done in a manner that is in the best interest of the child and has due regard for their evolving capacity and that informed consent is secured from the child and the parent or guardian. Adults often have strong views about how children ought to behave, and expect children’s content to show Programming and reflect only ideal patterns of behaviour. However, content that is not based on children’s own needs and interests tends to be seen as artificial and irrelevant. Producers are encouraged to facilitate the participation of children in the development of children’s content in order to ensure relevance. There are further guidelines on children’s programming in the Language Policy on Content the Policy on Educational Content. 4.6 Sex, Nudity and Pornography Sex and nudity may be offensive to some people, and content providers are therefore encouraged to give their audiences adequate warning and to schedule such material when children are not expected to be in the audience in large numbers. Broadcasters and publishers are prohibited from carrying material classified as XX (sexually explicit) in terms of section 18 of the Film and Publications Act of 1996 (as amended), or material which, when judged in context, contains a scene or scenes, simulated or real, of any of the following: 4.6.1 4.6.2 4.6.3 4.6.4 4.6.5 A person who is, or is depicted as being, under the age of 18 participating in, engaging in, or assisting another person to engage in sexual conduct or a lewd display of nudity; Explicitly violent sexual conduct; Bestiality; rape, incest, conduct or an act which is degrading of human beings; Child pornography; and (as defined in section 1 of the Criminal Law (Sexual Offences and Related Matters) Amendment Act, 2007 (Act No.32 of 2007) Explicit sexual conduct that degrades a person in the sense that it advocates a particular form of hatred based on gender and that constitutes incitement to cause harm. In terms of the BCCSA Free To-Air Code, the restrictions do not apply to bona fide scientific or documentary programmes, or dramatic material which, when judged in context, is of such a nature. The BCCSA Code also requires scenes depicting sexual conduct to be broadcast only during the watershed period. Further, when an exception is made for a programme with a serious educational purpose, it should be approved in advance by the most senior programme executive, or a delegated alternative. The BCCSA Code provides that explicit portrayal of violent sexual behaviour is justifiable only in exceptional circumstances, and the above approval process is prescribed in this instance, too. 19 The SABC’s policy on the portrayal of sex and sexuality is to ensure that it is defensible in the context, and presented with tact and discretion. This, with adequate advisories, should make for greater acceptability to the viewing public. When representation of sex is justified, it should generally be reserved for after 22:30. It is worth remembering, though, that if a series on sex were made for adolescents, there would be no point in offering it late at night. Exceptions may also be allowed for nature documentaries, content that have a serious educational purpose, or where the representation is a graphical illustration (delineated in cartoons or diagrams), but these are to be approved by the channel head. When topics of sexual nature feature in news, documentaries and discussions, programme makers should observe the need for careful scheduling and consumer advice. Tactful handling can help prevent the most sensitive of subjects from giving widespread offence. Overall, any programme that deals with sex and sexuality should be treated with care, and without sensationalism. Just as the SABC does not condone racist material, or gratuitous violence, it does not present sexual violence, or exploitative or non-consensual sexual relations, as acceptable. Whereas most of the negative reaction from the public is prompted by depiction, even discussion of sex attracts some criticism. However, it is the SABC’s responsibility as a public service media entity to encourage debate and open discussion of sex, sexuality and sexual roles. 4.7 4.7.1 Content Sponsorship The SABC complies with ICASA’s regulations on content sponsorship. ICASA defines sponsorship as direct or indirect financing, whether partial or total, of the production or transmission of broadcast programme material by an advertiser or person seeking to promote their activities or products. 4.7.2 ICASA regulates programme sponsorship and seeks to ensure that editorial control remains with the SABC. To this end, the regulations stipulate that if there is any depiction during a sponsored programme of the name or logo of whoever provides the sponsorship, that depiction should be subordinate to the content of the programme. The regulations also provide that where there is programme sponsorship, the sponsor’s association with the programme has to be stated clearly, both before and after the programme 4.7.3 Channel Heads, Editors, Programme Managers, and Commercial Enterprises, have a duty to ensure that the SABC is in compliance with these regulations. 20 4.8 Infomercials ICASA has developed rules for infomercials, with which the SABC complies. These provide that: 4.8.1 4.8.2 4.8.3 infomercials may not be carried during prime time, or during children’s programmes; infomercials must be labelled in such a way as to make it clear that they are not programme material; and no more than two hours of infomercials per day are allowed in the performance period (05:00 23:00) of each channel. In addition to the above, ICASA encourages broadcasters to ensure that infomercials are not carried on all the free-to-air channels at the same time. Channel Heads, Editors, Programme Managers, and Commercial Enterprises, have a duty to ensure that the SABC is in compliance with these regulations. Programming FAIR AND BALANCED REPORTING News 22 News 5. Policy on News and Editorial Content 5.1 Introduction The SABC occupies a distinct position of trust in the lives of its audiences. It is the most extensive, all-inclusive and diverse news organisation in South Africa. The SABC considers it a duty to provide compelling, independently produced, bias-free, credible and useful top-quality news, information and analysis, which the public can trust in their daily decision making about their lives, in participating in processes geared at enhancing, and advancing the country’s democracy and in building a common future. The Act and the ECA, the BCCSA and Press Codes and the SABC’s Editorial Policies set out the editorial tenets for news and current affairs services. These are to be read, understood and observed by every member of SABC’s news staff. This policy covers all news, current affairs and information services of the SABC across all platforms. 5.2 5.2.1 Editorial Independence and Impartiality The SABC recognises the centrality of news and information in advancing human development, social and economic growth, and in protecting and strengthening democracy. Consequently, and within the context of South Africa’s history, social justice and human progress are at the core of its storytelling. 5.2.2 Through this policy, the SABC is well positioned to meet the challenge of telling the South African story with compassion, determination and resolution, while creating forums where South Africans from every walk of life can communicate ideas about their daily experiences and aspirations. 5.2.3 The SABC commits to offer news content that is ethical, substantial and diverse, and analysis that is authentic and meaningful to the South African public. This means that content offerings should reflect plurality of views, diversity of opinion and be inclusive of all spheres of South African life across language, culture, gender, class, race and geographical boundaries 5.2.4 For the SABC to achieve editorial objectives that are beyond reproach, its journalists have the moral and ethical obligation to uphold the highest journalistic editorial ethical standards consistently and diligently. 5.2.5 In gathering and delivering news, current affairs and information as credible public good, SABC journalists and all newsroom staff must demonstrate such values as integrity in the manner they conduct themselves, transparency in the execution of their craft, rigour in dealing with sources of information, robustness in interrogating issues of public interest, resoluteness in demanding accountability, and fairness in the treatment of their story subjects. The need for SABC journalists to be upright, independent and impartial is at the heart of public trust. 5.2.6 The SABC’s freedom of expression and its journalistic, creative and editorial independence is guaranteed and protected in law. The principle of editorial independence is therefore fundamental to the operations of the public service media and especially important to the functions of the SABC’s news division. 5.2.7 The SABC is committed to upholding the independence of its news service and, flowing from this policy, the news division will develop its own internal guidelines on how to entrench this independence and deal with potential conflicts of interest in the newsroom. These guidelines deal with involvement of reporters in political organisations and declarations of financial or family interests, including how gifts and free travel are to be dealt with. As a public institution, the SABC is often itself the subject of its own news reports. When reporting on itself, the SABC ensures that its news service does so fairly, transparently, fully and without any interference from either the Board or its News and Editorial Subcommittee. 5.2.8 Through the News and Editorial Subcommittee, the SABC Board shall exercise oversight to: a. protect the public broadcaster’s editorial and programming independence as set out in the Editorial Policies; and b. ensure accountability for the compliance and adherence with these Editorial Policies, taking News into account that management retain operational responsibility for the enforcement of the policies across the Corporation. 5.3 23 history of South Africa, and that South Africa is part of Africa, it is the SABC’s responsibility to endeavour to represent Africa and African stories fairly and diversely. Editorial Guidelines The SABC’s public interest obligation is what gives meaning to its right to freedom of expression. In fulfilling its public duty, SABC news staff should at all times bear in mind that the right to freedom of expression comes with enormous obligations, the primary one being the duty to provide untrammelled news and information to the public. In executing their public responsibilities, all news staff should uphold the highest professionalism and ethical standards by committing to: 5.3.1 report, contextualise, and present news and current affairs honestly, accurately and transparently and to disclose all essential facts and information and not conceal relevant, available facts, or distorting by wrong or improper emphasis; 5.3.2 not allow commercial, political, state, interest groups and personal considerations to influence SABC’s editorial decisions. The SABC is expected to provide compelling news and current affairs content and as part of this duty should evaluate, analyse and critically appraise government policies and programmes. Owing to its legally protected editorial independence, the SABC is not the mouthpiece of the government of the day or a state broadcaster; 5.3.3 strive for balance by presenting a plurality of views at all times, and particularly on matters of national importance; 5.3.4 be guided by the public interest, news value and editorial merit in making decisions on coverage; 5.3.5 be mindful that fairness does not require editorial staff to be unquestioning and report passively; 5.3.6 not accept gifts, favours, free travel, special treatment, or privileges that could compromise SABC’s editorial integrity, and any such offer is to be disclosed; 5.3.7 promote and foster open dialogue and engagement with audiences and create opportunities for the public to discuss issues on local, social, political, economic and national concern; 5.3.8 consciously work to eliminate inequalities in terms of coverage and access to news and information by reaching even the more rural and remote areas; 5.3.9 Tell stories from a South African point of view and deal with issues that are important to South Africans. This includes local, African and global issues; and 5.3.10 Contextualise for South Africans their life as global citizens, and to recount the story of South Africa in all its variety and complexity. Given the The BCCSA and Press Codes also require journalists to report news truthfully, accurately and impartially. In this regard; 5.3.11 The staff may not allow their professional judgement to be influenced by pressures from political, commercial or other sectional interests. 5.3.12 As professionals, SABC journalists and all its news staff have personal opinions, beliefs and preferences arising from social, educational, cultural and other forms of nurturing. South Africa’s apartheid past and individual experiences in living through that period, also accentuates differences that could create unfairness and partiality, or perceptions of bias. It is the responsibility of SABC journalists and editorial staff to ensure that these forms of individual and collective nurturing do not lead to any form or perception of inequity or prejudice. 5.3.13 SABC news coverage should be accurate, fair, impartial and balanced. The public justifiably expects SABC news and current affairs content to not reflect personal views of editorial staff. In assigning stories and other content, SABC editors should be sensitive to published views, associations and backgrounds, so as to avoid any perception of bias, or of vulnerability to undue influence. 5.3.14 For the SABC to retain its credibility and maintain public trust, accuracy is imperative. Research for any news content has to be thorough, and be checked and cross-checked. Verification is also an important tool for ensuring accuracy. News agencies or SABC correspondents should verify national and international reports that are not obtained first hand. News and current affairs stories and feeds taken from international broadcasters, bureaux and correspondents are to be acknowledged, and to be consistent with SABC editorial policies and standards. 5.3.15 SABC editorial staff should always endeavour to present stories in a fair and balanced manner. Every attempt should be made to include a right of reply when required to ensure such balance and fairness in the same story. When exceptional circumstances make it impossible to achieve fairness and balance, or when damaging criticism of an individual or institution is presented, those criticised should be afforded the right to reply in a subsequent programme, with comparable prominence. With the best of intentions and efforts, mistakes still happen. When a serious factual error has been made, it 24 should be admitted and corrected as soon as it is realised on all platforms where it has been used, and afforded proportionate coverage relative to the scale and gravity of the error. The BCCSA and Press Codes require any rectification to be presented with such a degree of prominence and timing as may be adequate and fair in the circumstances so as to attract attention readily. 5.4 Protected Comment As provided for in the Press Code, SABC journalists shall be entitled to comment upon or report on any actions or events of public interest. Comment or criticism is protected even if extreme, unjust, unbalanced, exaggerated and prejudiced, under the following circumstance when it: 5.4.1 5.4.2 5.4.3 5.4.4 expresses an honestly-held opinion; is without malice; is on a matter of public interest; has taken fair account of all material facts that are substantially true; and 5.4.5 is presented in such manner that it appears clearly to be comment. 5.5 Language and Tone in News It is important for the SABC to get its facts and use of language correctly. Given our nation’s divided history and previously unequal learning systems, the use of South African languages should always consider the needs and sensitivities of the audiences. This means that: 5.5.1 Language usage and its tone of language should take account of different cultures, abilities, classes and experiences and avoid exaggeration, value judgement, unnecessary provocation, and lack of objectivity and or balance. 5.5.2 All content on all platforms should carry warnings in cases of unavoidable offensive language. In circumstance such as live coverage, it is difficult to anticipate such and where possible a pre-emptive verbal warning or permanent textual warning should be carried. 5.5.3 News content produced for children should at all times ensure that the use of language is suitable for children and meets the standard for the best interest of the child. 5.5.4 In instances where African Languages are involved, inaccuracies easily creep in when stories are translated. Therefore, only staff who have the required language skills should translate stories, and they should do so accurately and fairly. Further guidelines on language use are laid out in the Policy on Programming and Publishing and the Language Policy on Content. News 5.6 Interviewing 5.6.1 Interviews are an important tool of journalism. In order to achieve the objective of an interview to break new ground and get new information, it is important for interviewing to be purposeful and well researched. 5.6.2 For an interview to be productive and successful, it is important to inform an interviewee of the purpose of the interview, its duration and any other relevant matter, and to establish how he or she prefers to be addressed. 5.6.3 Care should be taken when interviewing people who do not have any experience of news media. 5.6.4 Allowance should be made for possible language barrier, confusion and misunderstanding, difficulty of expression, that may arise when an interview is conducted in a language other than the interviewee’s home language. If necessary, an interviewer should repeat questions and confirm that the interviewee has a clear understanding of what is asked, and may request the interviewee to clarify answers. Assumptions should be avoided at all costs as well as the temptation to reconstruct an interviewee’s responses later. The interview is the opportunity to do so. 5.6.5 Conversely, interviewers are increasingly faced with interviewees who attempt to steer the interview on their own course. In such cases, interruptions may be justified. Any unwillingness to answer questions should be shown up, but this should be done calmly and respectfully. 5.6.6 In commissioning and producing economics and business content, SABC news staff should ensure a diversity of views and schools of thought, and not limit the voices to orthodox perspectives. Such content should be presented in a balanced, fair and accurate manner. 5.6.7 SABC will strive to interview and access a diversity of voices, including those from marginalised groups, with due consideration for the ethics and public interest involved, as well as the interest of those being interviewed. 5.7 Analysts, Experts and Specialist Commentators 5.7.1 The SABC’s principle of providing a full spectrum of opinions, perspectives and comment also applies to selection and use of guests, analysts and specialist commentators. This requires editorial staff to choose, as participants, people who have a wide range of views, opinions and perspectives, and are drawn from all over the country. Such individuals should be required to declare any vested interest they may have in the matter to be discussed. While various analysts and commentators may be used frequently due to either availability or expertise, dedicated resident analysts are 5.7.2 News frowned upon as the arrangement may lead to single narratives and lack of plurality. Use of high quality and skilled experts must be considered at all times and editorial discretion must be exercised where necessary. 5.7.3 Priority must be given to ensure gender balance in the selection of guests. 5.7.4 Blacklisting of people for whatever reason will not be tolerated. 5.7.5 Diverse views and opinions should be accepted. However, incitement of violence, hate speech and propaganda for war will not be tolerated. 5.7.6 Specialist expertise must be used to bring authority and meaning to complex issues. 5.7.7 Tough searching questions must be asked of those who hold public office and others who are accountable in their respective spheres. 5.7.8 Editorials, analysis, commentary, and points of view must be held to the same standards of factual accuracy as news content. 5.8 5.8.5 As a matter of policy, the SABC does not use hidden cameras and microphones to gather news. In exceptional circumstances such as where there is suspected illegal, antisocial or fraudulent activity, or a clear and significant abuse of public trust, and where alternative means of newsgathering are impossible, the use of such equipment might be in the public interest. If so, the matter is to be referred to the Editor-in-Chief who will, in making the final decision, also consult the SABCs Legal Department. 5.9 Paying for Information 5.9.1 The BCCSA Code for Subscription Services and Press Codes prohibit paying criminals and informants for information, unless compelling public societal interests indicate otherwise. As a matter of policy, the SABC does not pay people for information. In circumstances where compelling public interest and the right to know are involved, and access to information cannot be gained by other means, the matter shall be referred to the Editor-in-Chief for a decision. When payment has been made, this fact is to be disclosed as part of the news item. 5.9.2 Investigative Journalism Investigative journalism, to which the SABC has made an important contribution, is a key feature of the pubic news service. SABC investigative journalism plays a vital part in pursuing matters of public concern systematically through innovative and reliable journalism, making it possible to access information that is crucial to the construction of a democratic society. As a general rule, and given its potential effect on the lives of a large part of society, investigative journalism at the SABC always takes into account the relative importance of an issue. In executing investigative assignments, the following must be considered: 5.8.1 25 Minor matters should not be dealt with when more significant issues warrant attention. 5.8.2 Although investigative journalism is robust and thorough in its examination of issues, it also has to adhere to the highest ethical and journalistic standards, be in the public interest, offer valuable information and authentic analysis, promote public dialogue, and enable the public to form their own opinions. 5.8.3 Given its nature, investigative journalism frequently involves legal considerations, and on such occasions the advice of the Legal Department is to be sought. 5.8.4 As a rule, SABC journalists work in the open and their journalistic practice is transparent. Clandestine methods of gathering news and information should be used with due regard to the law, the right to privacy, and the significance of the information. If it were to become necessary and in the public interest to gather information to which the public normally does not have access, the matter should be referred to the relevant Editor and or Editor-in-Chief.   5.10 Opinion Surveys in News Content 5.10.1 Surveys are methods used to discover facts, uncover attitudes and confirm hypotheses. However, to ensure the validity and reliability of the findings of such research, it has to be done according to proven scientific methods. 5.10.2 Before broadcasting the results of non-SABC surveys, journalists should obtain information on the methods used and the main results of the survey; seek the opinion of experts in the field on the validity of the methods used and interpretation of the findings. 5.10.3 The SABC may also conduct its own public opinion surveys, for which it takes full accountability. The Head of News Research shall be responsible for the design, questionnaires and interpretation of the results, after consultation with relevant Editor and or Editor-in-Chief. 5.10.4 Statements gathered (live or pre-recorded) from people chosen at random - vox pops - are not scientific surveys. These should be presented solely to illustrate the range and texture of popular opinion on a topical issue. Therefore, there should be no suggestion, explicit or implicit, that views gathered in such a survey reflect wider public opinion. 5.11 Protection of Sources 5.11.1 The SABC firmly upholds the principle of journalistic freedom and sees the protection 26 News of a journalist’s sources as a key element of this principle. At times, information that ought to be given to the public is available to journalists only through confidential sources. If the confidentiality of such sources were not respected, it would restrict the free flow of information in a free and democratic society. 5.11.2 In the event of a source not wanting to be identified publicly, the SABC uses the information obtained only when the source is known to the journalist and has prima facie credibility; the journalist has checked the reliability of the source and obtained corroboratory evidence from other relevant sources; and the identity and bona fides of the confidential source have been disclosed to the Editor-in-Chief. 5.11.3 When the protection of a source becomes a legal matter, the SABC does not advise its staff to refuse to obey an order of a court, but makes its legal counsel available for advice and to present legal argument in court to protect the source. citizens under the age of 18 are referred to as children. The SABC must ensure that children are accommodated and treated as human beings who have a voice and rights that must be affirmed. 5.12.7 At the same time, recognition of their vulnerabilities is paramount and topics with and about children must be treated with absolute sensitivity, and the best interest of the child is to be safeguarded. 5.12.8 The editorial staff must familiarise themselves with the various laws aimed at protecting children and the SABC’s legislative, regulatory and policy frameworks. SABC News shall not broadcast or publish any material that is unsuitable for children during the times when large numbers of children are expected to be available. Consent for an interview must be sought from the child, guardian or any other authority in loco parentis. In interviewing children in distress editorial staff must take care not to induce secondary trauma. 5.12 5.13 Gender, Children and Under-Represented Communities 5.12.1 Democracy and the need for inclusion places an important responsibility on the SABC to include its news services, consciously and with due prominence, the perspectives and opinions of women who are making a crucial contribution to the political, social and economic life of South Africa. 5.12.2 The SABC should strive to deal with gender inequality, bias and discrimination in editorial content by ensuring fair, balanced and nondiscriminatory portrayal of women, children and under-covered groups in news. 5.12.3 Journalists and all news staff should ensure that women, children and under-covered groups equitably participate in news and information content. This should include the Lesbian, Gay, Bisexual, and Transgender, Intersex and Questioning (LGBTIQ) community and people with disabilities. 5.12.4 In exploring experts for analysis, persons with disabilities and of different sexual orientation are to be given equal opportunity on the basis of capability. The sexual orientation or disability need not be mentioned if it has no relevance to the content at hand. In such cases, use of derogatory terms in any language should be avoided at all cost. 5.12.5 Where possible, honorifics ad titles should be gender neutral, for example, chairman or chairlady becomes chairperson. 5.12.6 Children’s rights are enshrined in section 28 (2) of the South African Constitution. In addition, other rights in other sections of the Constitution also apply to them. South African Privacy and Dignity 5.13.1 Promoting and protecting human dignity is the cornerstone of the South African Constitution. Therefore, as a public service media entity, the SABC has a unique responsibility to protect and respect human dignity and the right to privacy. 5.13.2 The SABC has a duty to uphold the Bill of Rights and to respect the dignity and private lives of individuals. For this reason and at all times SABC journalists and all news staff should respect individuals’ right to privacy, and not violate such privacy unless it is justifiable and in the public interest. The Policy on Programming and Publishing provides a comprehensive treatment of the SABC’s approach to matters of privacy. 5.14 Reporting on Suffering and Distress 5.14.1 In terms of the SABC Editorial Code, all news staff are circumspect in covering brutality, violence, atrocities and personal grief. 5.14.2 When covering accidents, disasters or conflict, the SABC should always give a full, accurate and factual account of relevant matters such as time, location and casualty figures. 5.14.3 Providing content recklessly and asking intrusive questions in a manner that may cause unnecessary and excessive distress or anxiety to those in grief must be avoided at all times. 5.14.4 SABC editorial staff must cover accidents, disasters and loss of human lives with compassion and sensitivity that is frank and genuine. News Consequences of tragic events or disasters call for considerable sensitivity on the part of the SABC’s editorial staff. Reporting on such events should be premised on the following well established principles: 5.14.5 Intrusive and graphic visuals of the dead should not be shown unless doing so is absolutely necessary and in the public interest. 5.14.6 Those injured or grieving should not be put under any pressure to give interviews. 5.14.7 As far as reasonably possible, next of kin should not first hear of bad news such as the death of a loved one through news reportage. 5.14.8 A funeral should be covered only with the permission of the family, and treated sensitively and without intrusion, unless public interest considerations are apparent. 5.14.9 The time of day of transmission, before or after the watershed, and audience sensibilities should always be considered. 5.14.10 When the content may be deemed offensive and disturbing to some viewers or children, a warning to that effect should be given. 5.14.11 News content should be prepared bearing in mind that children watch television during the day and early evening, especially when school are in recess. This requires explicit warnings about content that contains graphic details and visuals of particularly disturbing nature. 5.14.12 In its coverage of crime, the SABC should avoid a sensationalist approach that has no context or explanation. The public news service should report not only on the event, but also the human consequences and the subsequent judicial processes, as well as the potential causes and possible solutions to the issue. 5.14.13 In covering issues of gender-based violence, rape, child abuse, substance abuse and other serious crimes, as well as self-harm, and attempts to take life, the SABC acknowledges the possibility of secondary trauma that audiences may experience. Accordingly, the SABC will endeavour in such cases to ensure that information where audiences can seek help or support is provided, for example help line such as Life Line, Child Line, Rape Crisis, SADAG and others. These guidelines are elaborated on further in the Policy on Programming and Publishing. 5.15 National Events and Schedule Changes 5.15.1 The SABC gives full or extended live coverage of events of national importance. In scheduling these events, editorial staff should take into account that they inevitably result in schedule changes. Such events may include the opening of Parliament, the budget speech, state occasions such as visits by foreign dignitaries 27 and category-designated funerals; major commemorative occasions, and the proceedings of commissions of inquiry. 5.15.2 Other events that may warrant live coverage and involve scheduling and programming changes include major Parliamentary debates, the opening of provincial legislatures, and significant conferences of the major political parties. Live coverage of events of national importance requires approval of heads of the relevant platforms, in consultation with senior management. 5.15.3 When an event of national importance is of a party political nature, editorial staff are to ensure that the SABC policies on objectivity, accuracy, fairness, impartiality and balance are adhered to. The Language Policy on Content outlines further requirements for coverage events of national importance. 5.16 Live Productions Live productions have a number of inherent risks. Some can be foreseen and mitigated against while others are spontaneous and risk bound. Briefings with the entire production team are necessary to caution of such risks, how to identify these, and to report these before and/or as and when they happen. Other related issues that may stem out of live productions are: 5.16.1 Insults and or emotional inducing language; 5.16.2 Pejorative comments; 5.16.3 Defamatory remarks; and 5.16.4 Inaccuracies and wrong pronunciation of names/countries 5.17 Allocation of Resources 5.17.1 The SABC commits itself to ensuring fair allocation of financial, human and technical resources. In particular, attention is given to the African and Sign Language services, so that the needs of the audiences are met and requirements of delivering offerings of excellent quality are fulfilled. 5.17.2 In allocating its resources, the SABC takes into account the historical imbalances between English and Afrikaans on the one hand, and the nine African languages on the other. Moreover, the SABC takes into account that radio, owing to its reach and intimate nature and for historical reasons, remains the only medium accessible for receiving essential news and information for many. Special attention is therefore paid to developing and expanding offering on services that target language-specific audiences. 28 5.18 Universal Access to News Content Through its Universal Service and Access Policy, which is described separately, the SABC ensures that its language services are accessible to all South Africans. 5.19 Guidelines for Equitable Treatment of Language in News 5.19.1 The term equitable means fair and reasonable, but not necessarily equal treatment. In this regard, the SABC aims to provide for every official language on its multiple platforms, while ensuring that content offerings are accessible to as wide an audience as possible. 5.19.2 Ideally, and owing to resource availability, the national television service should be complemented by providing regional services as was intended by the Act, to ensure fair representation of all regions on the SABC’s television platform. However, advancements in technology and the SABC’s ever expanding multiplatform services are to be taken advantage of to ensure that this objective is still achieved, albeit differently, more efficiently and to a greater benefit for the audiences. 5.19.3 Equitability is achieved through a combination of means, including unilingual and multilingual content across all platforms. 5.19.4 Effort should be made to explore the use of technologies such as subtitling to ensure that content offerings are accessible to the audiences. At times this objective is met the best by offerings provided cognate or widely understood languages. When this is applied, the SABC should rotate the use of languages in any cognate group in order to achieve equitability. In striving to achieve equitability, the following matters are taken into account: 5.19.5 The overall time allocated to each language; 5.19.6 Scheduling of programmes when the target audiences are available; 5.19.7 The range of programme genres available in each language; and 5.19.8 Financial and other resources for programmes in each of the official languages. In determining allocation of time to each language, the SABC has due regard to: 5.19.9 The number of home language speakers in the coverage area of a platform; 5.19.10 The geographical spread of the language; 5.19.11 The extent to which members of a language community are able to understand other languages; 5.19.12 The extent of marginalisation of the language; 5.19.13 The extent to which it is understood by other News South Africans; and 5.19.14 Available resources. These criteria are intended to ensure that all the languages receive air time, but not necessarily in equal amounts. Moreover, when these criteria are applied effectively, a greater amount of time allocated to language-specific services should be dedicated to more widely spoken or shared languages, while committing to special initiatives for marginalised languages. 5.20 Election Broadcasts The News Editorial Policy is applicable both during elections and outside of election periods. Outside of elections, the SABC approaches its coverage of political parties as it does its coverage of all other newsmakers. It is guided by its commitment to editorial independence, accuracy, impartiality, plurality, balance and inclusion. As such this policy does not deal specifically with the coverage of political parties outside of an election period, as such coverage is subject to the BCCSA and Press Codes. Coverage of election periods must adhere to ICASA regulations, in addition to editorial values and journalistic practice. The following matters are worth noting during election periods: 5.20.1 News coverage during elections is a testing time for the SABC. This is because it is during elections in particular that commitment to editorial independence, impartiality, transparency and balance is scrutinised closely and evaluated determinedly. 5.20.2 Election broadcasts are regulated by the ECA and ICASA’s regulations, namely, the National and Provincial Party Elections Broadcasts and Political Advertisements Regulations. During an election period, the SABC is bound to comply with additional ICASA guidelines on equitable coverage of political parties, that are applicable only during an election period. 5.20.3 Notwithstanding the additional requirements, news decisions on coverage during election periods have, as is the case between elections, to be based on news value and editorial merit, and take account of the need to ensure that attention is given to thorough examination of the views, policies and campaigns of all the main political parties. 5.20.4 Elections can also be a testing time for the SABC’s editorial staff, who may experience pressure from political parties seeking to influence editorial decisions. While remaining courteous, staff should always refer complaints to the appropriate authority, ICASA. 5.20.5 News staff are required to study, understand and observe the statutory provisions on election coverage in the ECA (see sections 56, 57, 58, and 59) and ICASA’s regulations. These requirements include the limitations on Party News 5.20.6 5.20.7 5.20.8 5.20.9 5.20.10 5.21 Election Broadcasts, the time to be made available to political parties, the duration and scheduling of Party Election Broadcasts, and political advertising during election periods. News staff should also familiarise themselves with any internal guidelines developed for election coverage, including policies such as the National and Provincial Party Elections Broadcasts and Political Advertisements Regulations. No employees other than editorial staff may engage in any editorial decision making. As is the case outside election periods, editorial decision making is a legally-protected exclusive domain of designated editorial staff. No member of the editorial staff of the SABC may engage in any public or tacit declaration of support for any political party. This involves a prohibition on wearing party regalia, electioneering and posing for pictures with any of the parties to the election coverage. The SABC shall, in compliance with the ECA, cease party election broadcasts 48 hours before the polling period begins. Coverage of political activities and campaign shall be ended 48 hours before the polling period begins, to allow time to deal with outstanding complaints, and to avoid situations where continued coverage may give rise to demands for the right to reply too close to the start of the voting period. Restrictions on Sponsorship of News-Related Content The SABC’s approach to the sponsorship of news, current affairs and information programmes takes into account our public and commercial services’ programming responsibilities, applicable legal and regulatory requirements as stipulated from time to time by ICASA, and the overall performance and well-being of our stations and channels. 5.21.1 Like ICASA, the SABC seeks to ensure that editorial control and content decision remain the domain of the newsroom. Accordingly, it is the responsibility of the SABC’s editorial staff to ensure that editorial independence and integrity are not influenced by the presence of advertising and sponsorship. 5.21.2 Sponsorship of news and heavily-editorial current affairs content on television is prohibited by ICASA, and is therefore not allowed by the SABC. 5.21.3 In line with the fact that it is currently permitted by ICASA, the SABC’s policy is to allow for the sponsorship of radio news and current affairs content. 5.21.4 Weather forecasts and sports content that 29 form part of television news bulletins may be sponsored. 5.21.5 Any product placement within news and current affairs content is strictly forbidden. 5.21.6 However, content offerings that fall within the Informal Knowledge Building (IKB) category, although they may be produced by the news division, could be sponsored. In such instances, these must be disclosed fully and prominently during the said programmes. These include but are not limited to, travel shows, themed industry exhibitions, inserts on health tips, personal and business finance inserts. While produced with same editorial rigour, these programmes are not hard news, current affairs or investigative in nature, but merely informative and educational. Due care must be taken to ensure that such sponsorship does not influence decisions on how the content is treated editorially. 5.21.7 It should be indicated clearly when an outside organisation has contributed to the cost of newsgathering, such as travelling and accommodation costs. 32 Language 6.2 6. Language Policy on Content 6.1 Introduction As South Africa’s public service media, the SABC embraces its constitutional duty to treat all official languages equitably, and with equal respect. The Constitution also recognises the need to promote South African Sign Language and the Khoi, Nama and San languages. The SABC is conscious of its role in facilitating the fulfilment of language rights of individuals and communities. This Language Policy is derived further from the Corporation’s commitment to freedom of expression, which is protected by the Constitution, including the right of all South Africans to receive and impart information. The SABC recognises that: freedom of expression can be realised fully only when every South African can inform and be informed in their language of choice. Access to meaningful information also empowers South Africans to participate effectively in every facet of society. 6.1.2 language plays a crucial role in promoting and attaining the goals of strengthening democracy, and protecting and developing the country’s uniquely diverse cultures. 6.1.3 development and usage of languages is closely linked to the development of culture and identity. 6.1.4 owing to its virtual universal accessibility and use, the SABC has a unique responsibility to provide content offerings that promote the development of a national identity while supporting the advancement of languages and cultures. 6.1.5 South Africa, and consequently the SABC, is faced with the daunting challenge of bringing marginalised national languages, cultures and identities into the mainstream, so that they can develop and flourish, and become a core part of the nation-building project. Statement of Commitment This policy takes into account the provisions of the Constitution on language, and a range of legislative and regulatory requirements, in particular those contained in the Act, the ECA and ICASA policies and regulations. Drawing on these, the SABC commits itself to: 6.2.1 providing a range of distinctive, creative, compelling and top quality content in all official languages across its platforms; 6.2.2 reflecting the needs of each language community in its content offerings; 6.2.3 maintaining distinct and separate radio services in each of the official languages; 6.2.4 treating all official languages equitably on all its platforms; 6.2.5 integrating the South African Sign Language into its offerings as a means of making content accessible to people with hearing disabilities; and 6.2.6 including other non-official languages spoken in South Africa, with particular emphasis on the Khoi, Nama and San languages. In acting on these commitments the SABC will be guided by the following: 6.2.7 6.2.8 6.1.1 6.2.9 6.2.10 6.2.11 6.3 The need for key institutions, in addition to the SABC, to take practical and positive steps to treat all the official languages fairly; The need to address the marginalisation of indigenous languages and the South African Sign Language in recognition of the impact of the previous systematic deprecation of those languages; The obligation to reflect the linguistic and cultural diversity, and multilingual nature of South Africa while promoting national unity; The SABC’s responsibility to be responsive to the needs of all South Africans, including persons with disabilities.; and The importance of language in communication as the carrier of values, attitudes, culture and expression. Aims and Objectives The SABC’s primary role is to make its content accessible to all its audiences. In this regard language is fundamental to meaningful communication. In line with this, the SABC aims to: 6.3.1 6.3.2 inform, educate and entertain South Africans in their home or preferred languages; promote understanding and acceptance of and between the linguistic and cultural groups in South Africa; Language 6.3.3 contribute to continual development of the official languages and the South African Sign Language; and 6.3.4 promote multilingualism in South Africa. 6.4 Scope of the Policy The SABC is, in terms of the Act and the ECA, required to provide content in all the official languages and to cater specifically for the needs of persons with disabilities. Accordingly, this is an overarching policy, affecting many activities of the Corporation. This policy should therefore be considered when the SABC: 6.4.1 6.4.2 6.4.3 6.4.4 6.4.5 6.4.6 6.4.7 6.5 develops strategic plans for the Corporation; develops business plans and budgets for the Corporation; formulates content strategies, policies and plans for its multiplatform environment; determines training needs and initiatives; develops audience research projects to gauge the needs of viewers and listeners and to assess response to content offerings; formulates plans for universal service and access to content; and investigates and formulates plans for the use of innovative technology. Language in National Events Coverage The SABC is committed to covering events of national importance, such as the annual State of the Nation Address and the Budget Speech, that warrant full or extended live coverage. Coverage of these events gives South Africans access to important and relevant information about the state and direction of the country. On such occasions, the SABC ensures that they are covered by all of its language-specific content services and on all platforms. To this end, the language services collaborate with, and complement, one another’s content plans and schedules. The Policy on News and Editorial Content provides more information on coverage of national importance. 6.6 6.6.1 Language in Content Offerings In fulfilling its duty to protect and nurture South Africa’s official languages, the SABC strives to ensure that they are all spoken correctly. In doing so the SABC commits itself to celebrating the rich diversity of dialects and accents in each language group. 6.6.2 The SABC recognises that languages are dynamic, continually developing and adapting to circumstances, and that content offerings should therefore take into account the evolution of languages. 33 6.6.3 Moreover, language usage should accord with the content genre. It is fair to assume that more formal language would be used in news content, whereas more conversational, colloquial or everyday language would be used in drama. 6.6.4 Language provisioning in content services should also take account of social expectations and values of different language groups, and the right of every South African to be treated with respect and dignity. 6.6.5 Language usage in content services should therefore avoid giving offence and causing hurt unnecessarily. 6.6.6 Use of language in content should encourage respect and concern for everyone, and be free of elements such as prejudice, racist and sexist connotations. The Programming and Publishing Policy and the News Editorial Policy expand further on this issue. 6.7 Operating Principles In striving to play its part in reaching these common national goals, the SABC’s Language Policy on Content takes account of, and is shaped by, a number of operating principles: 6.7.1 Use of groupings of cognate, shared and widely understood languages so as to make the most cost effective use of scarce resources; 6.7.2 Paying special attention to marginalised languages; 6.7.3 Attainment of language objectives, including the use of South African Sign Language, in targeted content genres; 6.7.4 Combined use of unilingual and multilingual content offerings; 6.7.5 Coverage of events of national importance to promote the development of national identity, unity and nation building; 6.7.6 Equitable allocation of resources to achieve quality in content on all platforms; 6.7.7 Application of appropriate technologies to achieve language coverage and access objectives; 6.7.8 Use of research to understand audiences’ language needs in content; 6.7.9 Introduction of annual plans to focus implementation and monitoring of the Language Policy; and 6.7.10 Development of mutually beneficial relationships with key social partners, notably the Pan South African Language Board (PANSALB), South African Translators’ Institute (SATI), the African Languages Association of Southern Africa, and many others. 6.8 Language in Radio Content and Services Radio is still the most widely consumed and most 34 accessible medium in South Africa. As audiences have fragmented increasingly into niche markets, this has put a special responsibility on the SABC to offer South Africans a wide range of content offerings irrespective of age, income or language. Accordingly, the SABC is charged with providing quality radio services in all official languages. In making this pledge the SABC notes: 6.8.1 The crucial part radio plays in the lives of many South Africans, as it is often the only medium available to them in their home or preferred language, and in many instances the only medium available at all; 6.8.2 The under-development of previously marginalised languages in South Africa, which must be redressed if the commitment to delivering excellent content offerings on radio is to be met; and 6.8.3 The unique part radio plays in promoting people’s right to receive information, to express themselves, and to inform others. The SABC further commits itself to providing quality radio content in non-official South African languages, in particular in the Khoi, Nama and San languages. 6.9 Content Guidelines A language service should be sensitive to and reflect the needs and lifestyles of the speakers of that language, including those of children, young people, urban and rural dwellers, and the elderly 6.9.1 A language service should provide content in genres such as news and information, children’s/ educational programmes, and entertainment; 6.9.2 Content should aim to reflect the realities of the target audience, while recognising their right to a wide range of content offerings from throughout South Africa and the world; and 6.9.3 Content should aim to foster unity and a common South African identity. 6.10 Language 6.11.1 Children require informative, educational and entertaining programmes of excellent quality, in their home or preferred languages, aimed specifically at addressing their needs and instilling a sense of pride in their culture and language. These needs vary according to the circumstances and ages of children, from preschool to school going and adolescence. 6.11.2 Language-specific content on radio platforms has a critical role in nurturing and developing children’s language capacity, and cultural knowledge and experiences. 6.11.3 Targeted content offerings can also assist in promoting understanding between children of different linguistic and cultural communities. The SABC addresses the needs of children in its languagespecific radio and television content by offering services that cater specifically for them. The Policy on Programming and Publishing gives more information on children’s content. 6.12 Allocation of Resources for Language Services 6.12.1 The SABC commits itself to ensuring fair allocation of financial and other resources to all language services. This is to enable and support initiatives geared at providing content of excellent quality, and allowing audiences to access and consume content in their preferred languages. 6.12.2 In allocating its resources, the SABC takes into account the historical discrepancies between English and Afrikaans, which were prioritised in the past, and the nine official African languages that still require development and support. 6.13 Language Services and Universal Access Through its Universal Service and Access Policy, which is described separately, the SABC ensures that its language services are accessible to South Africans who speak those languages. Language in News and Information Services 6.13.1 Languages on Television The SABC recognises the important part news and information programmes play in enabling every South African to participate effectively, and from an informed basis, in human development and building democracy. Meaningful access to information is therefore essential, and involves not only reporting events, but analysing issues of significance as well. Noting this, the SABC is committed to providing comprehensive news and current affairs content on radio in all official languages. 6.11 Language in Children’s Content The Act requires the SABC programming needs as follows: to meet children’s The SABC is committed to treating all the county’s official languages equitably on its television content. This is achieved across the television portfolio. Since the prime time block is relatively short (18h00-22h00), over time, the SABC commits to increasing the air-time of other official but marginalised languages, by implementing innovative ways for providing content equitably. One such strategy being explored is to the scheduling of content in different languages on and across SABC television channels in a complementary way. In fulfilling its mandate to provide content in all official languages on television, the SABC takes into account the following: Language 6.13.1.1 The Constitutional requirement to treat all official languages equitably; 6.13.1.2 The comparatively little television air time available, especially in prime time, and the complexities of allocating time equitably to all official languages; 6.13.1.3 The similarities and differences between official languages. For example, certain languages are part of a cognate group while others are not but are shared and understood by different communities. Some are neither commonly understood nor widely spoken. In addition, some language communities are much bigger than others; 6.13.1.4 The realisation that certain languages are recognised as being more marginalised than others (XiTsonga, TshiVenda, SiSwati and IsiNdebele) and the additional responsibility this places on the SABC to take cognisance of such in content offerings; 6.13.1.5 The need to address historical marginalisation of the vast majority of South Africans and their languages, in order to realise the rights of all people to equality and dignity; and 6.13.1.6 The unique potential of television to showcase cultures and languages creatively; to nurture people’s knowledge and experience of one another, and to contribute to developing a national identity. 6.13.2 Guidelines for Equitable Treatment of Languages 6.13.2.1 The term equitable does not mean equal but fair and reasonable. In this regard, the SABC aims to use all official languages in its offerings on television, while ensuring that content is accessible to the greater majority of the public. 6.13.2.2 Equitability is achieved through a combination of means, including unilingual and multilingual offerings. 6.13.2.3 The SABC strives to use technologies such as subtitling, to ensure that content is accessible to a wider audience. At times this objective is best met by broadcasting in cognate or widely understood languages. When this is applied, the SABC rotates the use of languages in any cognate group in order to achieve equitability. In striving to achieve equitability, the following matters are taken into account: 6.13.2.4 The overall time allocated to each official language; 6.13.2.5 Scheduling of content when target audiences are available; 6.13.2.6 The range of content genres available in each official language; and 6.13.2.7 Financial and other resources for content in each official language. 35 In determining allocation of time to each language, the SABC has due regard to: 6.13.2.8 The number of home language speakers in the coverage area of a channel; 6.13.2.9 The geographical spread of the language; 6.13.2.10 The extent to which members of a language community are able to understand other Languages; 6.13.2.11 The extent of marginalisation of the language; 6.13.2.12 The extent to which it is understood by other South Africans; and 6.13.2.13 Available resources. These criteria are intended to ensure that all the languages receive some air time, but not necessarily in equal amounts. Moreover, when these criteria are applied effectively, a greater amount of air-time is allocated to more widely spoken or shared languages, while a concerted effort is being made to allocate resource to marginalised languages, including new technologies. 6.13.3 Language Access and Television Content For television content, the SABC commits itself to: 6.13.3.1 broadcast a range of top quality content in each of the official languages across its television portfolio, in order to meet the information, education and entertainment needs of audiences comprehensively; 6.13.3.2 produce and screen news and information, children’s educational content, and drama in different languages, while not neglecting other genres; 6.13.3.3 ensure that content in specific languages are broadcast at times to suit most of the members of the target audience in that language community; 6.13.3.4 provide content broadcast programmes in the different languages that reflect the needs, lifestyles and circumstances of speakers of that language, including the children, young people, urban and rural dwellers, and the elderly; 6.13.3.5 ensure that scheduling of content is sensitive to audiences’ right to have access to a range of content offerings in their home and preferred languages. To this end, television programmes across the channels are scheduled in a complementary manner; 6.13.3.6 ascertain that programmes are aimed at fostering unity and a common South African identity, and at promoting cross-cultural knowledge, appreciation and understanding; and 6.13.3.7 ensure that SABC creatively combines unilingual and multilingual programmes, and uses broadcasting technologies such as subtitling, to reach its language goals. 36 6.13.4 Unilingual and Multingual Content 6.13.4.1 It is the duty of the SABC to ensure that across its television portfolio, some of the content is dedicated to each official language. A content offering is classified as being in an official language if most of the material is in that language. 6.13.4.2 The SABC is conscious of the part multilingual content can play in promoting knowledge and understanding of the country’s diversity of languages and cultures. When used creatively, such content can also reach out to wider audiences. 6.13.4.3 For that reason, the SABC actively encourages production of meaningful multilingual content as a means of attaining its language objectives. Multilingual content is that which includes substantial amounts of more than one official language. 6.13.5 Language Access and Television News The SABC is specifically obligated to provide comprehensive news and information programmes. As stated previously in the Policy on News and Editorial Content, meaningful access to information involves not only covering events, but providing substantial analysis of issues surrounding such events. Accordingly, the following principles apply to all the SABC news, current affairs and information on television: 6.13.5.1 The SABC provides television news content in all official languages, and is sensitive to audience availability in scheduling news content; 6.13.5.2 Given the constraints of channel air time, the SABC makes use of cognate languages for news content on a rotational basis, and widely understood languages to meet its public obligation; and 6.13.5.3 The SABC ensures that news content, including current affairs and documentaries, serve the needs of different language communities. In meeting this commitment, the SABC takes due cognisance of the fact that several languages are cognate to each other, or widely understood. 6.13.6 Language Access and National Events Coverage 6.13.6.1 The SABC is committed to broadcasting events of national importance that warrant partial, full or extended live coverage, such as the State of the Nation address, the Budget speech and commissions of inquiry. When such events are televised, the SABC strives to ensure that the content is accessible to the widest range of South African language communities. 6.13.6.2 This is achieved, and can be further enhanced through the use of a combination of cognate languages and widely understood languages, Language and innovative use of technology such as multiple soundtracks, subtitling, and Sign Language. 6.13.6.3 Regarding the above, the SABC strives to broadcast events of national importance in the six language groups as provided for in the National Language Policy Framework, developed by the Department of Arts and Culture. The Policy on News and Editorial Content provides extensive information on the coverage of events of national importance. 6.13.7 Language Access and Children’s Programmes 6.13.7.1 Children require informative, educational and entertaining programming of excellent quality, in their home and/or preferred languages that are aimed specifically at addressing their needs and instilling a sense of pride in their culture and language. These needs vary according to the circumstances and ages of children, from pre-school to school going and adolescence. The SABC recognises that many children, particularly pre-school children, understand only their home language. 6.13.7.2 The SABC strives to provide a range of top quality educational, informative and entertaining television content for children of different age groups that are responsive to their language needs. This can be accomplished by such means as dubbing, multilingual content and subtitling that is age appropriate. 6.13.7.3 When acquiring and scheduling children’s programmes the SABC takes children’s language requirements into account. More information on children’s content is detailed in the Programming and Publishing Policy. 6.13.8 Language Access and Drama 6.13.8.1 Drama provides a unique means of telling our South African stories, and learning from and about one another. The SABC broadcasts top quality South African dramas on television and soon to be extended to digital platforms via video-on-demand and other Over-the-Top (OTT) platforms. 6.13.8.2 SABC dramas include and reflect South African languages and cultures. 6.13.8.3 The SABC further undertakes to investigate innovative and creative ways of ensuring that such dramas are accessible to as wide a range of audiences as possible, such as multilingual productions, subtitling, and dubbing. 6.13.9 Language Access and People with Disabilities 6.13.9.1 The SABC is committed to responding to the broadcasting needs of all its audiences across the board. Responding effectively to the needs Language of people with disabilities is an important part of its public mandate. 6.13.9.2 The SABC develops specific plans to facilitate access to its content for persons with disabilities. 6.13.9.3 Provision of content in South African Sign Language, as a recognised South African language, is one of the means of meeting the needs of people with hearing disabilities. While the provision of Sign Language Interpreting (SLI) facilities enables access to content by persons with hearing disabilities, it also creates interaction with, and understanding of this community, while contributing to nation building. 6.13.9.4 The SABC is progressively expanding the amount of content that is SLI-enabled, starting with selected news and current affairs content, and events of national importance. 6.13.9.5 Special efforts are being made to provide SLI when programmes are recorded in front of live audiences. Such efforts facilitate participation by people with hearing disabilities. 6.13.9.6 While focusing on providing content that is SLI-enabled, the SABC also acknowledges that a holistic approach is needed to address the needs of the community. In this regard, closed captioning may offer a viable solution. 6.13.9.7 The SABC will continue to explore various technologies which may assist in resolving some of the current barriers. 6.13.9.8 In meeting the content needs of people with visual impairment, the SABC undertakes to investigate the use of innovative technologies such as audio-description. 6.13.10 Language Access and Allocation of Resources The SABC acknowledges that it is currently faced with limited air time and other programming and publishing resources. In order to achieve its language objectives, the SABC undertakes to achieve fair and equitable allocation of financial and other resources when commissioning, scheduling and publishing content in official languages. 6.13.11 Languages and Universal Service and Access The Act requires that, as circumstances permit, a wide variety of content in the country’s official languages should be extended to all South Africans. The SABC undertakes to pursue this objective with full consideration of its multiplatform environment, through the Universal Service and Access Policy. 6.13.12 Language Access and Research The needs and demographics of our language communities are changing and evolving continually. Since the SABC is committed to serving the content needs of these communities, it undertakes to research 37 these needs regularly, and to ensure that such research informs its commissioning, scheduling and publishing strategies. The SABC also makes use of research to assess whether the strategies and innovations it implements meet audience expectations adequately. 6.13.13 Language Access and Technology The SABC recognises that technology offers innovative means of meeting the challenges of providing content in the country’s official languages and South African Sign Language. The organisation therefore commits to undertaking relevant research into the creative use of technologies to facilitate the implementation of its mandate as it pertains to language. 6.13.14 Relationships with other Organisations The SABC recognises that it has a significant part to play in contributing to equitable treatment of the country’s official languages and the South African Sign Language. It believes it can fulfil its responsibilities effectively in collaboration with other organisations that have also been established to further these aims, such as the Pan South African Language Board. The SABC also considers other institutions like universities, professional bodies, research institutes and subject experts in this regard. It therefore establishes mutually-beneficial working relationships with such organisations, to facilitate compliance with the Language Policy on Content outlined in this document. 6.13.15 Monitoring and Implementation The SABC Board requires management to submit an annual forward-looking language action plan that identifies future goals arising from this policy. A summary of achievements of the previous year is also to be attached to the language action plan in order to facilitate a review of the achievements, opportunities and challenges. Universal SerVIces 40 Universal Services 7. Universal Service and Access Policy The SABC as a major player in the audio-visual content services sector, has a crucial role to play in bridging the digital divide, by providing Universal Service and Access in South Africa. Sections 8 (a), (b) and (d) of the Act enjoins the SABC to work towards making its services available throughout the Republic of South Africa, by providing sound and television broadcasting services whether by analogue or digital means in its public broadcasting service. The SABC envisions itself as a digitised national public broadcaster that provides compelling informative, educational and entertaining content via all platforms. It further provides programming content in all official languages including the Xu! and Kwe! This document sets out a policy on Universal Service and Access for the SABC’s services. It aims to facilitate the provision of a comprehensive end-to-end public service for all South Africans. 7.1 Context of this Policy The changes in the audio-visual content industry, in line with technological advancements, make it imperative for this policy to be flexible and dynamic. The aim is to ensure that uncertainty about future developments in the South African broadcasting sector do not discourage much needed future investment in the sector, nor hamper planning efforts to expand coverage and services. Legislation, regulations and public policy directives in the South African communications sector are already framed in the language of technological convergence, in which the general approach to regulation is based on a three-tier structure: networks, services and content. Regulatory developments in highly industrialised regions of the world have already adapted to the needs of addressing convergence. They have also relied heavily on competition law to regulate transmission networks and trade in audio-visual products and services. Separate policies and regulations have been developed to deal with the goals of cultural and social policy, including extension of public service media. From a technological point of view, the developments in OTT services and digital broadcasting technology are enabling the SABC to provide Universal Service and Access through its multiplatform services. Apart from OTT services, Digital Satellite technology (DTH), Digital Terrestrial Television (DTT) and Digital Audio Broadcasting (DAB) have all introduced innovations that allow people to access the SABC services on multiple platforms and devices. 7.2 Scope of the Policy The SABC’s commitment to Universal Service and Access extends across its multiplatform portfolio. To this end, all SABC Radio and Television Services are available on the DTH, DTT and OTT platforms. Through this policy the SABC seeks to provide public audio-visual content services to every citizen in the country using its multiplatform services. In line with the SABC’s mission to provide “content that is accessible to all, anytime, anywhere” the following are to be considered: 7.2.1 7.2.2 7.2.3 7.3 SABC mobile and online offerings should include low bandwidth formats; ensure that online and social media content is usable on data zero-rated platforms; and utilise low bandwidth multimedia distribution platforms where possible to ensure that its online content is universally accessible. Monitoring and Implementation An annual action plan will be submitted to the Board by the executive management for monitoring and evaluation purposes. A summary of the previous year’s achievements should be attached to the Universal Access and Service annual plan to review performance, track delivery and monitor emerging trends for future exploitation. Local Content 42 Local Content 8. Policy on Local Content 8.1 Introduction As South Africa’s public service media entity, the SABC is firmly committed to supporting the South African music and production industries by providing local television content and South African music. The SABC believes that South African such content plays a key part in reflecting and celebrating our country’s diverse people and cultures. Given the neglect and degradation of many aspects of South African cultural expression in the past, local content on the public broadcaster helps to restore a sense of pride and dignity in local music, performance, film and the arts. This, in turn, assists in furthering important public interest goals such as nation-building and reconciliation. The SABC also recognises that providing local content on its multiplatform service can contribute to promoting growth of the music, production and associated cultural industries. Nevertheless, the ability of the SABC services to provide high levels of local content is influenced by market dynamics in the local music and production industries. For instance, the music industry does not always produce South African music consistently across all the music formats. As far as television content is concerned, the cost of local material is usually significantly more than international programmes. In an environment where programming is funded primarily through advertising, there is also pressure on the SABC to screen material that would draw audiences and revenue. This is the context in which the SABC operates, and in which it seeks to demonstrate its commitment to providing local content, while taking into account intense competition from new streaming services locally and globally. 8.2 Requirements and Commitments Various regulatory and legislative requirements applicable to the SABC in terms of local content were taken into account in developing this policy. They include those of the Act , the ECA and relevant ICASA regulations. Specifically, the SABC has been guided by the requirements that: 8.2.1 content services, viewed collectively, develop and protect national and regional identity, culture and character; 8.2.2 the SABC to take into account the needs of its audiences; 8.2.3 the SABC should showcase South African talent; 8.2.4 the SABC should reflect South African attitudes, opinions, ideas, values and artistic creativity; 8.2.5 the SABC should offer a plurality of views and a variety of news, analysis and information from a South African point of view; 8.2.6 that SABC needs to support the production of local content by South Africans, particularly by historically disadvantaged people; and 8.2.7 the SABC should consider specific quotas set by ICASA for local television content, independent production and South African music on the SABC’s public and commercial services. In accordance with those obligations, the SABC commits itself to the following: 8.2.8 ensuring that local television content is a significant and visible part of its schedules, throughout the scheduling period and in prime time, in line with the quotas prescribed by ICASA; 8.2.9 ensuring that it commissions a significant amount of its local television content from the independent production industry, in line with the quotas prescribed by ICASA; and 8.2.10 Continuing to play a high level and wide variety of South African music across the SABC radio stations, in line with the quotas prescribed by ICASA. 8.3 Scope of the Policy The imperative to deliver significant levels of local content has a direct impact on the SABC’s multiplatform environment, unless stated otherwise. These services are obligated to comply with the ICASA regulations and licence conditions on local content. This Local Content Policy should be read together with those requirements and applies to all the SABC’s designated platforms, and may evolve with the changes in the operating and technological environment. It is the responsibility of the licensees to comply with local content quotas. These Local Content 43 quotas make no distinction between public and commercial services. platforms prescribe and agree the proportions of local content with Content Hub, News, Education and Sport. The policy should be considered when the SABC: 8.3.1 8.3.2 8.3.3 develops strategic plans and/or Key Performance Indicators for the Corporation; develops business plans and budgets for the Corporation and its services; and formulates content strategies, policies and plans for all platforms. 8.4 Local Content on Television 8.4.1 Definition of Local Television Content Local television content is defined in the ECA as a television programme (excluding broadcasts of sports events and compilations of them, advertisements, teletext and continuity announcements) that is produced by a South African broadcaster, or by South African people. All the quotas are set out in regulations which may be reviewed by ICASA when necessary. 8.4.4 It is the responsibility of each television channel to ensure compliance with the local content quotas. Policy and Regulatory Affairs works with the channels to ensure consistency in the designation and measurement of local content, and adequate forecasting to identify any potential difficulties in meeting the quotas. Policy and Regulatory Affairs consolidates the information received from channels and compiles it into reports that are submitted to top management. Annual local content compliance figures and ICASA figures are published in the Corporation’s Annual Report to Parliament. 8.4.5 8.4.2 SABC’s Local Content Approach on Television Definition of Independent Production Also in the ECA, an independent production is defined as a production of local television content by a person who is not employed directly or indirectly by a broadcaster, or by a person who is not controlled by, or in control of, any broadcasting licensee. 8.4.3 Television Compliance with Quotas Local Content Quotas for Television The SABC is bound by the local content and independent production quotas prescribed by ICASA. There are three sets of quotas for television: 8.4.3.1 Global local content quotas for each television bouquet. These stipulate that a percentage of the air time between 05:00 and 23:00 should be allocated to local content. The global quotas distinguish between public and commercial bouquets. 8.4.3.2 Genre quotas. These stipulate that if a television channel carries a certain genre of programming (such as drama), a percentage of that type of content is to be allocated to local content. The genres are defined in the ICASA regulations and span the following six areas: drama, informal knowledge building, and content for children, education, documentary and current affairs. In each case a minimum percentage is prescribed. These quotas also distinguish between public and commercial bouquets. 8.4.3.3 Independent production quotas. Here the stipulation is that a percentage of the total amount of local content aired must be allocated to independent television productions. These The following principles underpin the SABC’s approach to local content on television: 8.4.5.1 In line with the distinction between commercial and public service bouquets made by ICASA, the most significant delivery of local content is on the SABC’s public service platforms. The SABC believes it is appropriate for its public service platforms to have the most significant commitment to airing local material. 8.4.5.2 The SABC undertakes to provide a range of good quality local productions. This means the television portfolio as a whole airs local content in a variety of content genres targeted at different audiences. Taken collectively across the SABC’s television portfolio, this content should reflect South Africa’s diversity of people, provinces, languages, cultures and religions, while also being aligned to the needs of the audience. 8.4.5.3 The SABC is also aware that historically there has been a lack of good quality local material in African languages. It is a dual objective of this policy, and of the Language Policy on Content as well as the Policy on Programming and Publishing, for local African languages content to be seen on public service television channels. 8.4.5.4 The SABC is eager to support development of television content on the African content and, if possible, will endeavour to showcase such material, particularly on its public service platforms. 8.4.5.5 The SABC recognises that a productive and thriving relationship with the independent 44 production sector is essential for the provision of good quality local content. As part of its commitment to strengthening the relationship with this sector, the SABC has published a separate policy and procedures on Procurement of Local Content, which details the SABC’s policy and procedures for commissioning and acquiring local material. This policy also outlines the SABC’s approach to supporting Black Economic Empowerment in the production industry which it has identified as an important objective. 8.4.5.6 The SABC recognises that it is the industry’s biggest investor in skills development. Aligned to its investment in local content is a commitment to investing in empowerment and skills development processes that benefit the industry at large. 8.4.5.7 The SABC strives to engage more fruitfully with partner organisations in the film and television industry in order to support development and transformation of the local production industry. 8.5 Local Content on Radio 8.5.1 Definition of South African Music South African music as defined in the ECA is that in order to qualify as South African music, a musical work must meet at least two of the following criteria: 8.5.1.1 The lyrics are written by a South African citizen; 8.5.1.2 The music is composed by a South African citizen; 8.5.1.3 The music and/or lyrics are performed principally by musicians who are South African citizens; and 8.5.1.4 The musical work is a live performance recorded wholly in South Africa, or performed wholly in South Africa, and broadcast live in South Africa. Local Content are made to top management, and annual figures are published in the Corporation’s Annual Report to Parliament. 8.5.4 The following principles underpin the SABC’s support for South African music: 8.5.4.1 ICASA makes a distinction between the level of local content expected from public service stations and from commercial stations, and has set a higher quota for public service stations. The SABC concurs that its public service stations should lead the way in supporting South African music. 8.5.4.2 With 18 radio stations providing content in all official languages, and in a range of formats, SABC radio stations are uniquely placed to showcase the wide range of musical expression in South Africa. The SABC undertakes to use its stations effectively to explore and celebrate the diversity of South African music. 8.5.4.3 Whereas the allocation of air time to South African music will always be the primary means of supporting local music, the SABC believes there are a number of other equally effective interventions that SABC radio platforms are able to make in support of local music. The SABC gives publicity to local musicians through interviews, reviews and promotions. The stations, both public service and commercial, also stage live events every year in partnership with South African acts. 8.5.4.4 The SABC strives to support the development of music on the African continent, and where possible will showcase such music. 8.6 8.5.2 Monitoring and Implementation Radio Quotas for South African Music The SABC’s designated radio stations are obliged to comply with the South African music quotas prescribed by ICASA. These quotas stipulate that a percentage of the tracks played between 05:00 and 23:00 are to be South African. A distinction is made between public service and commercial radio. The quotas are reviewed by ICASA when necessary. 8.5.3 The SABC’s Approach to South African Music on Radio Radio Compliance with Quotas It is the responsibility of each radio station to ensure that they comply with the local content quotas applicable to them. They are assisted by the SABC’s Policy and Regulatory Affairs department in reporting their compliance to ICASA. Quarterly compliance reports The Board requires management to submit a forwardlooking annual local content action plan that identifies future goals arising from this policy. A summary of achievements of the previous year is to be attached to the local content action plan in order to facilitate a review of the achievements, opportunities and challenges. Religious Broadcastmg 46 Religion 9. Policy on Religious Content 9.1 Introduction South Africa is a multicultural and multi-faith society that is united by a common humanity and moral order. Within its diversity there are human values that call for the promotion of social harmony, national healing, reconciliation, social reconstruction and nation building. Most South Africans associate with a variety of faiths, beliefs and practices. The SABC has a public interest obligation to provide content in a manner that is unbiased and representative of South Africa’s multifaith character. In so doing, the SABC seeks to promote mutual respect for all faiths. The SABC’s content should therefore reflect South Africa’s major faiths, while allowing expression for those that do not have an extensive following. For the purposes of this policy, major faiths are understood to include Christianity, African Traditional Religion, Islam, Hinduism and Judaism. In its content, the SABC seeks to correct gender, racial, religious and resource allocation imbalances associated with faith-based offerings in the past. It further seeks to ensure that the distinctive identities of the traditions are reflected in a way that facilitates the moral objectives of justice, social harmony and the common good. Faithcentric content should play a meaningful part in the moral regeneration of South Africa. Such content should be provided in accordance with values that include: 9.1.1 Sensitivity to the diverse nature of South African society and the need for justice, healing and reconciliation; 9.1.2 Compassion and concern for human dignity and for all life, including the earth 9.1.3 A common South African identity; 9.1.4 Integrity, transparency and trust in all relationships; 9.1.5 Commitment to the independence and impartiality of the SABC, within the parameters of its accountability to the South African public; and 9.1.6 A spirit of co-operation between the SABC and the faith community. 9.2 Nature of Religious Content The following principles underpin the SABC’s approach to faith-based content: 9.2.1 In achieving its mandate, the SABC provides both faith-specific and multi-faith content. Faith-specific content should give the major religious groups the scope to celebrate their life of faith without censure. Multi-faith offerings - (programmes with content elements that are diverse) and inter faith offerings -(programmes that offer diverse voices and views on a theme), in addition to faith-specific content, should promote dialogue, respect and understanding among all the faith groupings in South Africa. In delivering faith-based content, the SABC should take advantage of its multiplatform environment. 9.2.2 Whereas faith-based content is aimed at complying with the SABC’s Programming and Publishing Policy, the organisation takes particular care to ensure that in such offerings there is sensitivity to the beliefs of others, and that no faith is attacked or undermined. 9.2.3 Faith-based programmes may not be used to solicit funds, or to support any content offerings of a political or ideological nature. Permission for fundraising, whether for emergency relief and/or social welfare causes, should be obtained from the SABC before the airing and publishing of the content. 9.2.4 The format of faith-based offerings and the choice of presenters should meet the technical, creative and professional criteria required by the SABC. 9.2.5 The SABC provides faith-based content in a variety of formats including documentaries, magazines and actuality. The aim of these is to encourage comment on matters of national concern, and to introduce people to faiths practised in South Africa and, where appropriate, elsewhere. Religion 47 The SABC sources faith-based content through its standard procurement procedures including commissioning, licensing, pre-sales and /or content that may be acquired at no cost to the Corporation or the supplier 9.2.7 Faith-based content should strive to be contextual and relevant, and reflect our African reality. It should be aimed at further correcting the neglect of African beliefs and cultures in the public media. This means that special attention should be given to African traditional faiths and cultures 9.2.8 The content should take account of regional factors, target audiences, language and cultural preferences, and the devotional needs of specific groups. the right to accept or reject an offer to purchase air time based on the material proposed; 9.4.4 In considering offers to purchase air time, the SABC gives preference to good quality local material; 9.4.5 Profits from the sale of air time to faith groups should be directed to the funding of religious content; 9.4.6 Scheduling of such air time is the prerogative of the SABC; 9.4.7 Sponsorship, fundraising, advertising and commercial branding in air time sold to faith groups is governed by the rules of SABC Airtime Sales; and 9.4.8 Operational Guidelines to guide transactions on air time sales are available on request. 9.3 9.5 9.2.6 Scheduling of Religious Content Faith-based content should not be confined to Sundays, or the fringes of schedules, but placed at times when audiences are available. It must be scheduled and published on days that are appropriate to individual faiths. 9.4 Paid Broadcasting and Religious Content In addition to its normal provision of faith-based content, the SABC may make air time available for purchasing by interested groups for broadcasting of their material. The sale of such air time should be negotiated on a commercial basis and be guided by the following: 9.4.1 9.4.2 9.4.3 The sale of air time to groups may in no way detract from the SABC’s mandate to provide faith-based content; The sale of air time to particular faith groups should be consistent with the time allocated to those groups, as determined every three years. Within this, the SABC shall also ensure that there is equitable representation of various denominations in faith groups; Content scheduled in slots that have been sold to faith groups is always to be consistent with the SABC’s Policy of Religious Content and all the other relevant policies. The SABC reserves Community Faith Committee (CFC) The SABC will establish the Community Faith Committee (CFC) as per the approval of the Board. The mandate of the CFC would be to advise the SABC of faith matters. The CFC will constitute a total of 15 members, 3 SABC Staff members and 12 representatives from major and minor faith groups. CFC members will serve under the Committee on a voluntary and ad hoc basis. The SABC will set the terms of reference for the CFC. 9.6 Monitoring and Implementation The Board requires management to submit an annual religious broadcasting action plan that identifies future goals arising from this policy. A summary of achievements from the previous year is to be attached in order to facilitate a review of the achievements, opportunities and challenges. BETTER EIUCATIONAL SHOWS Education 50 10. Policy on Educational Content 10.1 Introduction The SABC is required by legislation to inform, educate and entertain viewers and listeners. The provision of educational content is therefore essential to the implementation of its public service mandate. The SABC recognises that to right the wrongs inflicted by decades of apartheid education on the knowledge, literacy and skills profile of South Africa, requires the collective contribution of all educational authorities, institutions and individuals. The SABC recognises that through its content, it can make a unique contribution to this public imperative. Complementary to what is offered by schools, colleges, higher education institutions and work place training, SABC platforms can make the most significant contribution to learning. The SABC also acknowledges that an informed and educated citizenry is fundamental to the sustained development of South Africa. Through its educational content, it is well placed to advance national goals of equality, dignity and an inclusive society and works towards these ends. In fulfilling its educational mandate, the SABC is guided by the constitutionally-enshrined right of all South Africans to receive education, in the official languages of their choice where reasonably practicable. The SABC also aims to attain the goals set in the Act, the ECA, and the relevant policies and regulations. In particular, consideration is given to the requirement of the Act that the SABC’s public content services should: “include significant amounts of educational content, both curriculum-based and informal educative topics from a wide range of social, political and economic issues, including, but not limited to, human rights, health, early childhood development, agriculture, culture, justice and commerce and contributing to a shared South African consciousness and identity”. This Policy on Educational Content sets the framework within which the SABC implements this mandate and Education responds to the national literacy and skills development challenge. 10.2 Objectives The SABC commits itself to the following objectives for educational content: 10.2.1 To provide innovative educational content of excellent quality across SABC platforms, aimed at meeting the diverse formal and informal learning needs of all our audiences, including children, youth and adults. These include: (a) Content that supports the curriculum-based activities of the education and training sectors and cover a wide range of subjects and fields; and (b) Content that promotes public education on rural development and urban renewal, human resources development, citizens’ rights and responsibilities, healthy living, innovative solutions to personal, family and community challenges, national identity, culture and heritage. 10.2.2 To ensure that platforms in the SABC’s public content portfolio devote adequate time to educational content, and schedule them at times that are appropriate for the target audiences; 10.2.3 To ensure that platforms in the commercial portfolio support a culture of lifelong learning through informal knowledge-building initiatives that are relevant to their format and target audience; 10.2.4 To provide educational content in all official languages and, in selected genres, Sign Language, taking into account the language needs of each target audience; 10.2.5 To provide a significant amount of locally produced educational content, recognising that such offerings are often best for meeting the educational needs for South Africans. However, the SABC also recognises that it is important to expand audiences’ knowledge of the African continent and the rest of the world, and accordingly will ensure that internationally acquired content satisfy these goals; 10.2.6 To enhance the effectiveness of educational content by implementing a coherent education methodology that incorporates multimedia strategies such as the use of traditional and digital platforms; 10.2.7 To supplement educational methodologies through outreach programmes, where appropriate, in the form of training and support for users of materials aimed at deepening the educational impact of the content; and 10.2.8 To ensure that sufficient resources are apportioned for implementing the educational Education 51 mandate. To this end the SABC secures financial and other resources from a variety of sources, including the government and licence fees, private and international donors, advertising and sponsorship, co-productions and related content partnerships with a range of national, continental and international institutions. 10.3 Key Principles In providing educational content, the SABC is guided by the following principles: 10.3.1 The SABC ensures that educational content is relevant and appealing to targeted audiences, and with sensitivity reflects the diverse experiences and needs of all South Africans; 10.3.2 The SABC ensures that its educational content addresses imbalances in the historical provision of education, especially, but not exclusively, those based on race, gender and disability; 10.3.3 The SABC links its educational content to national priorities and needs, supporting the achievement of national educational goals, lifelong learning, and the association of educational and life experiences; and 10.3.4 The SABC builds strategic partnerships that enable it to provide effective and impactful educational content initiatives. 10.4 Scope of the Policy Designated platforms in the SABC diversified portfolio are required to comply with any legislation, regulations and licence conditions that are relevant to educational content. The Policy on Educational Content is also to be read together with the other relevant editorial policies including the Policy on Programming and Publishing, the Language Policy on Content, and the Universal Service and Access Policy. This Policy on Educational Content is considered when the SABC: 10.4.1 Develops strategic plans and budgets for the Corporation to meet its educational mandate; 10.4.2 Produces or commissions educational content; 10.4.3 Develops schedules for its multiplatform environment; 10.4.4 Procures international educational material. Every independent producer and consultant contracted to produce educational material for the SABC should be made aware of this policy. 10.5 Guidelines for Implementation 10.5.1 The SABC ensures that its services, in combination, provide a significant amount of educational content that complies with the objectives outlined in this policy. 10.5.2 At least one of SABC’s television channels should provide content specifically in support of the primary and secondary school curricula. This is supplemented by offerings on public service radio stations. 10.5.3 The SABC ensures that educational content is scheduled at times that are suitable for the target audiences. 10.5.4 All educational content has clear goals. Such goals and expected outcomes are established before the production, commissioning or acquisition of any educational content. 10.5.5 The SABC’s educational content business unit, together with the Commissioning Editors and Executive Producers responsible, is tasked with ensuring that these outcomes are achieved through creative and innovative content. 10.6 Guidelines for Scheduling Educational Content In scheduling educational content, the SABC should ensure that the material: 10.6.1 conforms to the highest production and publishing standards. A wide variety of content formats should be utilised to ensure that the aim of the offering is achieved creatively and is appropriate to the subject matter and target audience; 10.6.2 utilises innovative technologies and techniques (including dubbing, multilingual programming and subtitling) in order to increase the effectiveness and comprehensibility of content in different language communities; 10.6.3 is challenging and informative, aims to promote a culture of learning and teaching and supports skills-based learning. The basic tenet of all the educational content to impart knowledge and problem-solving skills, promote critical thinking and, when necessary, assist in changing attitudes and behaviour; 10.6.4 relates to the personal circumstances of the audiences, and seeks to impart the knowledge and skills that would help them to change their circumstances for the better; 10.6.5 assists in fostering a harmonious relationship between South Africans and the environment, and promote sustainable development; 10.6.6 complies with all the SABC editorial policies, including those on portrayal and stereotyping of people, violence, and the classification and 52 scheduling of programmes. It should seek not only to avoid stereotypes based, for example, on race, ethnicity and disability, but to challenge proactively any stereotype or bias, and so assist in changing attitudes; and 10.6.7 utilises wide a range of subject experts and interviewees, who, for example, are of different races, genders and physical abilities, and hold differing views, in order to reflect our diverse society. 10.7 Advertising and Educational Content The SABC will use every possible source of funding to meet its obligations in terms of this policy, including commercial sponsorship, subject to the following: 10.7.1 When a programme is required to be presented, wholly or in part, in a setting that simulates a place of business (for example, a supermarket), care should be taken in designing the setting, and the props used, to reduce identification with particular companies, brands or proprietors; 10.7.2 Content and material produced externally, or in created settings, may not be used to carry indirect commercial advertising; and 10.7.3 Care should be taken to avoid the exposure of advertising signs or other commercial identification in programme content. Where this is impossible, it is the responsibility of the producer, or the director, or both, to play down as much as possible such extraneous commercial exposure. 10.8 Public Mandate Aspects in Educational Content Arising from the Act, the SABC has identified the following educational content requirements: 10.8.1 10.8.2 10.8.3 10.8.4 10.8.5 10.8.6 Early Childhood Development; Children at Home; Formal Education; Youth Development; Adult and Human Resources Development; and Public Education. 10.8.1 Early Childhood Development Educational content for early childhood development is aimed at supporting the holistic development of young children (from 0 - 7). The SABC recognises that as relatively few South African children have access to any structured early childhood education, such content assists in preparing young children “to be ready to learn”. Educational content also supports the implementation of the national Grade R (Reception Year) curriculum. Moreover, this content equips caregivers with the Education knowledge and skills to facilitate and support the growth and development of young children. Early childhood development content should meet the following standards: a. Be stimulating, entertaining and engaging to the target audience; b. Develop children’s self-esteem; c. Enhance the target audience’s imagination; d. Reflect the personal experiences and cultures of the audience; e. Affirm children’s sense of self and place; f. Consider language needs and the needs of learners with disabilities; and g. Have a primary focus on health, nutrition and safety. 10.8.2 Children at Home Educational content for children at home is aimed at children of school going age who are not at school, and seeks to create the space for children to engage and express their thoughts and opinions on issues that affect them. Educational programming for children at home is required to meet the following standards: a. Be stimulating, entertaining, enabling children to learn, have fun and interact with others b. Consider language needs and the needs of learners with disabilities c. Promote healthy living, social awareness, selfesteem and an understanding of human rights d. Be focused primarily on science, technology, mathematics, economics and communication. 10.8.3 Formal Education Formal educational content affirms and support the development of Foundation Phase learners (ages 5-9) and Intermediate Phase learners (ages 9-13). Formal education content is required to support the implementation of the national school curriculum by providing resources of excellent quality developed specifically to assist both teachers and learners to achieve nationally set outcomes 10.8.4 Youth Development Educational content intended for youth development is aimed at promoting a culture of life-long learning among young people, both at and after school. a. Youth educational content should: b. aim to develop self-esteem among listeners and Education viewers and provide a platform for expression; c. contextualise young people’s realities, fears, concerns and needs; d. showcase youth solving problems, thinking critically, acting independently, developing creatively, intellectually, socially, cognitively and emotionally, and addressing, overcoming and transforming their future; and e. create an awareness of the rights and responsibilities of all citizens, including the youth, as contained in the Bill of Rights of the Constitution. 10.8.5 Adult and Human Resources Development Adult and human resources development content affirms the concept of life-long learning, and support development of the skills and knowledge needed for survival in a competitive and ever-evolving world. Content is aimed at meeting the formal and informal skills development needs of both the employed and the unemployed, and support South Africans in their occupational endeavours. They include adult literacy, skills development, educator development and entrepreneurial skills development. 10.8.6 Public Education Public educational content is aimed at offering the information, knowledge and skills South Africans need for effective participation and interaction in society. They promote the drive for life-long learning, and foster tolerance and understanding of one another and all our cultures. Such content enables people to take informed decisions, encourage critical thinking, and impart problem solving skills. 10.9 Research to Support Educational Content The SABC evaluates the impact of its educational content continually. Research is done to assess audience needs and to evaluate the effectiveness of the programmes. This includes audience research (e.g. to establish people’s needs) and formative and summative research which enables understanding of the contribution of content to audiences’ development. 10.10 Monitoring and Implementation An annual action plan that identifies educational priorities for each of the educational mandate areas indicated above, should be submitted to the Board. When necessary, these strategies are drafted in consultation with educational stakeholders. Implementation of these strategic plans is evaluated annually. 53 54 Complants Management Processes 11. Complaints Management Processes a. Public complaints that are sent directly to the SABC and relate to matters of policy, or compliance with the BCCSA Code, are dealt with by the office of the Broadcast Compliance Manager. When such complaints are received by the respective platforms, or in any other department, they should be referred to that office without delay. b. The SABC’s policy is to deal with every such complaint. The response is either prepared in consultation with, or communicated immediately to the management of the platform concerned, or the relevant SABC News editor. Platforms are encouraged and are required to take ownership of complaints relating to their services. c. Trends in complaints, and all the formal complaint processes are reported to Executive Management and the Board, regularly. ICASA regulations require accurate record-keeping of all complaints received, with bi-annual reports prepared for submission to ICASA by the Broadcast Compliance Department. 11.1 Complaints Lodged with the BCCSA 11.1.1 When a member of the public lodges a formal complaint with the BCCSA about a programme broadcast on any of the SABC services, the BCCSA notifies the SABC in writing, provides a copy of the complaint, and indicates whether a copy of the programme should accompany the written response from the SABC. 11.1.2 When the BCCSA requests material for review in any complaint process, the SABC is obliged to provide a complete copy of the programme as broadcast. This includes any on-screen and/ or verbal consumer advice. Where necessary, a transcription of the text is required, and/or the Final Control Sheet for the programme. The Broadcast Compliance Manager requests this material from the relevant service, and it should be supplied within three (3) days. 11.1.3 In consultation with the staff responsible for the broadcast in question and who may be asked to provide comments in writing, the Broadcast Compliance Manager prepares the SABC’s response to the complaint. This submission, together with the material requested, has to be delivered to the BCCSA’s premises within ten (10) working days of notification of the complaint. The formal process is then conducted in accordance with the current Procedure of the Commission (available on the Internet at http:// www.bccsa.co.za), which may be amended from time to time. When the BCCSA gives notice that a complaint is to be heard by the Tribunal, the Broadcast Compliance Manager takes the following steps: a. Requests the head of the service against which the complaint has been lodged to delegate an appropriate representative to attend the hearing (normally the person responsible for the programme in question); b. Applies to the SABC’s Head of Legal for assistance, if the BCCSA advises that the complainant will have legal representation; c. Prepares the SABC’s case; d. Consults, or refers a case to the Legal Department when the need arises; and e. Defends the SABC at the hearing, assisted by a legal consultant, if necessary. 11.1.4 When the BCCSA’s decision about a complaint, adjudication (by an individual commissioner), or judgement handed down by the Tribunal is received, the Broadcast Compliance Manager circulates it immediately to all the relevant staff. 11.1.5 On being found guilty of a breach of the BCCSA Code, a broadcaster may be reprimanded by the Commission, or required to take certain steps to rectify the situation, or instructed to broadcast a correction, retraction, or apology. Complants Management Processes 11.1.6 The BCCSA is also empowered to impose fines of up to R80 000 for serious infringements. 11.1.7 Records of formal complaints are kept, and their outcome is reflected in a report to Group Executive Committee on a monthly basis. 11.2 Complaints Lodged with Advertising Regulatory Board (ARB) 11.2.1 When a member of the public lodges a formal complaint with the ARB about self-promotional material broadcast on any of the SABC services, the ARB notifies the SABC in writing, provides a copy of the complaint, and requests a copy of the material for review by the Authority. If the Authority finds that the complaint is not “frivolous or vexatious”, the SABC may be called to a hearing and be subject to sanctions as set out in the Code of Advertising Practice. 11.2.2 The ARB has jurisdiction over television channels and radio station promotional materials that are broadcast on any SABC service (for example, an RSG promo flighted on SABC2, or an SABC3 promo on SAFM), or on any other broadcaster’s channel/station. The ARB does not have jurisdiction over a channel/station promo broadcast on the same channel/station (for example, an SABC3 promo flighted on SABC3). A promo for any SABC programme content that is flighted on the same SABC channel/station falls within the jurisdiction of the BCCSA. 11.2.3 Therefore, the Authority can entertain complaints about programme promos only if they are flighted on another broadcaster’s service, or if they are published in the print media, or placed on outdoor advertising (for example, billboards). 11.2.4 When the ARB requests material for review in any complaint process, the SABC is obligated to provide a copy of the promo. The Broadcast 55 Compliance Manager requests this material from the relevant department, and delivers it to the Authority within five (5) days. 11.2.5 If any of the Codes referred to in these policies including the Press Code, the BCCSA etc., are amended after the publication of the Editorial Policies, the SABC and its employees shall be required to comply with such amended codes notwithstanding the provision of these Editorial Policies. 11.3 Complaints Related to Contravention of SABC Editorial Policies 11.3.1. Complaints about any breach of the SABC’s Editorial Policies that are not received directly by the Policy and Regulatory Affairs department should be referred to the Broadcast Compliance Manager without delay. 11.3.2. In the event of a serious contravention of any aspect of the editorial policy, or repeated infringement, the matter is referred upwards as follows: a. Policy & Regulatory Affairs Office; b. Executive Producer or News/Commissioning Editor; c. Editor-in Chief. 11.4 Complaints Related to Contraventions of the Press Code The SABC subscribes to the Press Code of Ethics and Conduct for South African Print and Online Media (Press Code) which is administered by the SA Press Council and the Press Ombudsman. Complaints about any breach of the Press Code will be dealt with in accordance with the Press Council complaints mechanisms. 11. Review of the Editorial Policies The Policies shall be reviewed every Five Years. 56 12. Acknowledgements The SABC would like to express its gratitude to the following contributors: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 54. Ada Theron Andre Bee Andre Bekker Andrew Mashimo Andries J Kok Ayanda Nabe Ayanda Stuurman B Singh Bahais Of Mangaung Bayaphi Lawrence Benita Draai Bhekumuzi Mkhwanazi C. Naidoo Cynthia Pein Daddy Mabe Daniel Sibeko Deenadayalan Naidoo Deon Marais Derick Mbungele Dolfred Sihlangu Dollandsson Dr Faisal Suliman Dr Glenda Daniels Dumisani Enock Mkhonta Elsie Beauty Estelle Puren Etherl Sentle Faizul Khamker Farouk Khustari Fathima Moosa Fishunathi Mahlalela Franki Fouche Franz Kruger (Wits) G.G. Paulus G.C. Baker Godfrey Mathwenyego Jaabosigo Goolam Kolia Gordon Lesamane Gerrit Van Den Dool Hendrick Mokgehle Hitler Hlophe Izak Minnaar Jack Smit Jane Thompson Jayne Boccaleone Jenny Hallowes Jeremiah Daka Joe Steyn Joe Thamaga Joseph Mahlangu Kedibone Sentle Kenrich Botha Krish Pillay Leepile Mokhobo 55. 56. 57. 58. 59. 60. 61. 62. 63. 64. 65. 66. 67. 68. 69. 70. 71. 72. 73. 74. 75. 76. 77. 78. 79. 80. 81. 82. 83. 84. 85. 86. 87. 88. 89. 90. 91. 92. Lindani Mjezu Lionel Sieberhagen Lorraine Sparg Ludimo Magwaca Lukani Martin Theng Madoda Mditshwa (Inkolo Yesintu) Makhosana Msibi Makondelelea Ndou Mandla Dladla Mando Teledimo Mark Naicker Maruping Masilo Masilela Masilela Mduduzi Motaung Michael Khumalo Michael Masinya Miliza van der Merwe Miriam Hoosen Mmachigo Millicent Manase Mothibeli A Nyapholi Mothusi Dikwelana Mpho Mangole Mpho Talane Mr and Mrs Fourie Musawenkosi Ndlovu Muzi Mngomezulu Mxolisi Zuma N. Jombile Nazeer Alli Nchanyana Joseph Mafere Nomhle Motlou Pumudzo Tshirangwana Nthabi Dlamini Oswell Shane Dean P Kotze Petros Ngwenya Phemelo Ntshwe Phumudzo Tshirangwana 93. Princess Msibi 94. Quinton Lenyai 95. Rick Simpson 96. Romeo Qetsimani (SAMIC) 97. Rose Langmann 98. Rosemary Foster-Towne 99. Rudi Bisschoff 100. SAMNET 101. Sangeeta Naipal 102. Sello Samasilo Malakalaka 103. Shanitha Rathilal Bhageloo 104. Shuaib Appleby 105. Sigcau Hlahatsi 106. Sisa Tabata 107. Sizwe Mkhize 108. Stanely April 109. T. Giqwa 110. T.S. Makhwanya 111. Thabiso J Taba 112. Thabo Mokuoane 113. Thandisizwe Mgudlwa 114. Thato Sedupe 115. Thulani Mbatha 116. Tineke Pretorius 117. Tinyiko Sihlangu 118. Tirelo 119. Tlou Setumu 120. Ts Makhwanya 121. Tshepo Raymond Sithole 122. Tsholofelo Matshwisa 123. Vuyo Zela 124. V.P Smith 125. Xabiso Mbobo 126. Zahida Fakey 127. Right To Know 128. The Local Spiritual Assembly 129. Tape Aid for the Blind 130. Democratic Alliance (DA) 131. CWUSA 132. Musician Association of South Africa (MASA) 133. Government Information and Communications System (GCIS) 134. Muslim Judicial Council 135. Audiodescribe International 136. Gandhi Development Trust 137. Communicators Forum – Free State 138. Inkolo Kantu Traditional Organisation 139. Media Monitoring Africa (MMA) 140. Commission For Gender Equality 141. Elza-Lynne Kruger - The ICT Chamber For Disability 142. The Commission for the Promotion and Protection of the Rights of Cultural, Religious and Linguistic Communities (CRL) 57 13. List A - AD - ALASA - ARB - BCCSA - CRC - DAB - DAC - DTH - DTT - ECA - FPB - HIV/AIDS GBV - GCEO - GE - ICASA - IKB - L - LGBTIAQ - N - NAB - OTT - P - PA - PCCSA - PANSLB - PEB - PG - S - SABC - SADAG - SASL - SATI - SLI - UGC - V - of Acronyms Suitable for all ages Audio Description African Languages Association of Southern Africa Advertising Regulatory Board Broadcasting Complaints Commission of South Africa Community Religious Committees Digital Audio Broadcasting Department of Arts and Culture Direct to Home Digital Terrestrial Television Electronic Communications Act Film and Publications Board Human Immunodeficiency Virus / Acquired Immune Deficiency Syndrome Gender Based Violence Group Chief Executive Officer Group Executive Independent Communications Authority of South Africa Informal Knowledge Building Bad language, including profanity Lesbian, Gay, Bisexual, Transgender, Intersex, Asexual, Queer Nudity National Association of Broadcasters Over the Top Prejudice Political Advertising Press Council of South Africa Pan South African Language Board Party Election Broadcast Parental Guidance Sex South African Broadcasting Corporation South African Depression and Anxiety Group South African Sign Language South African Translators’ Institute Sign Language Interpreting User Generated Content Violence ?5.sz . 42%? gum?"ran; . K4 Im??mjzm