SBS EDITORIAL GUIDELINES 2006

(INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008)

SBS Editorial Guidelines 2006
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CONTENTS
1 2 INTRODUCTION EDITORIAL RESPONSIBILITY

2.1 2.2 2.3 2.4 2.5
2.6 3

Introduction Delegation Upward referral Management and employee responsibility Editorial issues in SBS Radio
Editorial issues for Online content LEGAL RESPONSIBILITY

3.1 3.2 3.3 3.4
4

Introduction Training and information Upward referral Online content
CONFLICT OF INTEREST

4.1 4.2 4.3 4.4
5

Introduction Definitions and situations Financial conflict of interest Radio producers
COMMERCIAL RELATIONSHIPS

5.1 5.2 5.3 5.4 5.5 5.6 5.7
6

Maintaining editorial independence Scheduling programs Program purchases Program production funding Advertising, sponsorship and SBS’s own promotions Placement of breaks in SBS television programs Corporate support: opportunities, limitations and acknowledgement
COMMUNITY ANNOUNCEMENTS ON SBS RADIO

6.1 6.2 6.3 6.4
7

Introduction: social, cultural, welfare and educational events Fundraising Personal announcements Government information campaigns
SUPPLY OF SBS PROGRAM MATERIAL TO THIRD PARTIES

7.1 7.2 7.3 7.4 7.5 7.6
8

Introduction Commercial and private use Contentious material Program-related material on the website Requests for non-SBS programming Variations
HANDLING PROGRAMMING COMPLAINTS, COMMENTS AND ENQUIRIES

8.1 8.2 8.3 8.4
9

Introduction Coordination of complaints handling SBS complaints handling procedure Complaints committee
HANDLING CORRESPONDENCE AND FEEDBACK GENERALLY

9.1 9.2 9.3 9.4
10

Introduction Telephone calls Written correspondence Privacy
ADVICE ON THE CODES OF PRACTICE AND EDITORIAL GUIDELINES

10.1 Strategy and Communications 10.2 Legal APPENDIX A: SBS Code of Conduct

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1

INTRODUCTION

The SBS Editorial Guidelines are integral to program making. They should be read in conjunction with the SBS Codes of Practice. At every point in the production process decisions are made: what to report, produce and commission. Then there are the underlying checks and balances that determine sound decision-making: editorial impartiality and responsibility, legal considerations and potential conflicts of interest. Finally, there are the procedures for responding to formal and informal program complaints. These Editorial Guidelines are the mechanism for good broadcasting. They ensure that SBS follows a model of transparency and integrity, upholds its Charter obligations, and meets its audiences’ expectations. The Guidelines have been revised to reflect industry changes, such as the advance of SBS Online content and the modification of SBS Television’s program break structure. The Guidelines, which are primarily for SBS program makers and content producers, are intended to provide information and points of reference to help them exercise their professional judgement at crucial junctures in their work process. Perhaps the most fundamental principle is ‘upward referral’. In other words “When in doubt, refer the issue to the next level of authority for guidance”. If you have any queries regarding the Codes or Guidelines, feel free to approach the Strategy and Communications division to seek advice. At all times, the overriding obligation of all program makers and content providers is to ensure SBS’s editorial integrity and independence. Shaun Brown
MANAGING DIRECTOR

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The Managing Director. including the Charter (in section 6 of the Act). acquiring or commissioning a program is in doubt about an editorial question.4 MANAGEMENT AND EMPLOYEE RESPONSIBILITY Management is responsible for ensuring that: • delegations are appropriate. If the employee does not refer the matter. Where someone presenting. 2. 2. 2. we must ensure that SBS’s commercial activities do not compromise SBS’s editorial integrity and independence. Decision makers in the editorial process who are uncertain about these matters must be able to obtain advice from higher up the editorial chain of responsibility. As part of our compliance with these rules. Areas where an employee may need guidance could include: program material which could breach the SBS Codes of Practice. and • any changes to procedures and delegations are quickly and clearly communicated to employees.3 UPWARD REFERRAL Employees are responsible for referring to the next level of authority any matter on which they need guidance. • editorial procedures are publicised within the workplace. Where the legal advice is that SBS would be at high risk if particular material were broadcast (i. but is not involved in day-to-day operations. Programs which are controversial or likely to have an out of the ordinary impact in the community must automatically be referred up.2 2. Employees who have editorial responsibility are expected to exercise that responsibility on a day-to-day basis. the Commonwealth Authorities and Companies Act 1997 and SBS’s own Codes of Practice (programming policies). there is a low prospect of successfully defending subsequent legal action). The Managing Director delegates various levels of responsibility to employees. regardless of other considerations the material should not go to air until the matter has been referred to at least the relevant division director or delegate. Upward referral protects individuals and enables SBS to allocate appropriate resources for dealing with important and sensitive issues. he or she is held responsible for the decision.2 DELEGATION The Board is responsible for SBS. or circumstances in which an employee is faced with inappropriate pressure related to what is or is not broadcast on SBS. Editorial matters which may have legal implications must be referred to the SBS Corporate Counsel through managers with editorial responsibility (see Guideline 3 Legal Responsibility). • there are procedures to deal quickly and efficiently with editorial matters. 1991 (SBS Act). SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 4/35 .1 EDITORIAL RESPONSIBILITY INTRODUCTION SBS is subject to the provisions of the Special Broadcasting Services Act. producing. the general law relating to broadcasting. is responsible to the Board for managing SBS and for the editorial output of the organisation. he or she must refer it to the next most senior person. situations of potential conflict of interest. Employees are responsible for ensuring that they understand the editorial procedures and for seeking clarification as necessary.e. • employees are made aware of the editorial procedures that apply to them. who is a Board member.

2.5 EDITORIAL ISSUES IN SBS RADIO 2. This should also include views from other communities where relevant. To reduce the potential for arousing community tension. It must reflect equitably the relevant facts and significant points of view. • national news services. SBS relies on many sources. encourage attendance. • Information must be truthful and not distorted to justify any particular position. • Producers must ensure that their programs do not become. • major international news agencies. 2.2.5. or are not used by individuals or organisations as vehicles for inflaming community tensions.2 Right of reply In some cases it may be appropriate for SBS to provide a right of reply (e.5. if possible. and • take particular care in selecting material drawn from homeland sources in and around the areas of conflict. • newspapers and journals published overseas and in Australia. where an individual or group has been directly criticised). • apply the resources of SBS’s News and Current Affairs to ensure that the issues and events are dealt with comprehensively and in line with SBS programming policies and practices. and deal fairly and ethically with all parties concerned. • news bulletins and current affairs programs provided by overseas broadcasters.5. including: • the SBS newsroom.5. News stories may contain details of rallies but they must not convey that SBS supports or opposes the rallies. Where producers intend to decline such a request. give attention to or give details of the event beyond its newsworthiness). Such rallies must not be promoted (i.3 Coverage of international conflicts Coverage of conflicts involving the homelands of different sections of SBS’s audiences has the potential to create tension. • Producers must be aware of potential conflicts of interest and not present a personal bias or partisan approach (refer to Guideline 4 Conflict of Interest). 2. SBS Radio has a responsibility to cover such conflicts. In doing so.5.g. and draw from their diverse range of community perspectives. convey support. SBS Radio language programs will cover controversial issues which have the potential to create tensions within the community. The Codes of Practice and the following associated principles must be followed: • Balance and objectivity are essential. Producers still have an obligation to make a balanced presentation. the matter should be first referred up. they should reflect their community or communities’ role in Australia’s multicultural society. in line with normal practices of editorial responsibility.5 Use of overseas and non-SBS sources In providing audiences with information about world events. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 5/35 . SBS Radio will: • anticipate. • the Internet. At times. potential problem areas. 2. • Every effort must be made to present differing sides of an issue in a fair and balanced manner and to ensure balance is achieved where possible within the same program and certainly over a reasonable time.1 Introduction SBS Radio producers have a responsibility to be sensitive to the wishes and needs of all sections of the community or communities which make up their potential audiences.e. The content of any reply is the prerogative of SBS. and • stringers and other contacts.4 Rallies SBS may cover public rallies as news stories and facilitate discussion of the central issues. • It may be that the overwhelming majority of a target audience for a particular language program has a strong view on a controversial issue.

2. • there are no other ways in which listeners can adequately access services of that faith. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 6/35 . For this reason.6). sermons and/or pronouncements unless there are exceptional circumstances.3) as well as the guideline on Commercial Relationships (Guideline 5. Attributing a story to another source does not relieve producers of responsibility to use their special knowledge and good judgement in assessing the accuracy and fairness of a story. SBS must be.5. • seek clarification about accessing government and other services. • providing airtime for religious faiths. sermon or pronouncement will denigrate another religion. impartial in its treatment of the many religions which are practised in Australia. 2. In choosing studio guests for talkback programs. they should refer the matter up.1).6 Talkback Talkback programs on SBS Radio provide a forum for the exchange of community opinion and offer unique opportunities for people from culturally and linguistically diverse backgrounds to: • express themselves on-air in their preferred languages.Producers are expected to use their contacts. speeches and press conferences. Management must be satisfied that: • there is a clearly demonstrated and overwhelming need for the programming. Where producers are unsure about whether or not they have the right to use any non-SBS material.5. provided that only the words of the subject are used and not those of a reporter or interviewer. SBS is a national broadcaster with a legislative Charter and its programs must have an identity which is independent of any particular religion or religions. Material from other media outlets or publications should be attributed to the relevant source/s. producers should ensure they comply with procedures on the presentation of controversial issues (including Guideline 2. • listeners who may practice other religions are catered for appropriately and not disadvantaged by the broadcast of the service.5. Particular care must be taken when: • selecting representatives of religious faiths for interview. This applies when using grabs from statements. Producers are obliged to assess news items objectively. from whatever source. In some cases it may be necessary to seek legal advice. and • there is no likelihood that the service. which may make the service particularly newsworthy. and must be seen to be. sermon or pronouncement.7 Religion Consistent with the Codes of Practice (Code 1. Most programs serve audiences comprising followers of several religious faiths and it may be appropriate for those religions to receive more attention in those programs than other religious denominations. Attribution to another news service is not needed when SBS can source a fact or statement directly to a named organisation or to an identified person such as an official or politician. SBS will not broadcast religious services. and • broadcasting religious services. knowledge and expertise to check sources for accuracy and reliability. SBS must be sensitive in dealing with issues of religion. and • question experts. SBS Radio will normally treat religion in the same way as other aspects of society. Any proposals must be approved by management on a case by case basis.

compliance or editorial restrictions which might limit or prevent reuse. Less sensitive areas may require post-moderation. leaves SBS open to possible legal action.6. Clips containing strong material (which is potentially disturbing to some audiences) should carry appropriate advice based on SBS’s Television Classification Code (Code 4). 2. SBS is publishing the material.2. As soon as SBS places any material on its website. web based chat forums. When SBS covers a sensitive or controversial matter.1 Introduction SBS follows the Codes of Practice in the selection and creation of online content produced by SBS and published on SBS’s website (on the domain www.3 Audio and video clips Where clips are selected to be reused or reversioned from programs which have already been broadcast. Context is important in deciding whether a link is appropriate and it is often useful to explain why SBS is offering the link. where the moderator checks the material after it has been posted. etc. SBS has editorial control over content and will remove anything that it considers to be inappropriate (e.) However. Producers should always check that SBS has the online rights for the material before it is published on SBS’s website. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 7/35 . 2.com. virtual environments.6. there are some issues of particular relevance to online content that require additional guidelines.6. bulletin boards etc. Sites dealing with sensitive areas may require pre-moderation.).6. material that is offensive.au) in so far as they apply to online content. That is.5 Links to websites outside SBS All links on the SBS website must be editorially justifiable. material cannot be accessed by visitors until someone with editorial authority has seen the material and decided it is suitable for placing on the Internet. 2. SBS should be seen to be impartial. is not applicable. SBS may offer a link to a site that does not share SBS’s editorial values. In some cases. The producer must check the contents of the site that is signposted before installing a link on an SBS page. 2.g.4 Non-broadcast material SBS may publish material on the Internet that has not been broadcast in any other form. User-generated material must be subject to moderation. (The five minutes per hour advertising limit. Legal and editorial considerations must be taken into account.sbs. producers should check that there are no outstanding legal.6. In all cases. The link should be regularly checked.6 EDITORIAL ISSUES FOR ONLINE CONTENT 2. for example. associated links should represent a reasonable range of views about the subject. The level of hosting and moderating will depend on an assessment of the likely participants and audience.g.2 User-generated content There are many different kinds of user-generated content on the Internet (e. Areas of the SBS website where there are opportunities for user-generated content must carry disclaimers to the effect that the comments posted are the opinions of the author and not SBS.) that SBS may choose to host that are related to its programming or Charter objectives.

Editorial material that has legal implications must be referred to the SBS Corporate Counsel. seven days a week and is able to obtain outside legal advice as required.6 for further guidance).4 ONLINE CONTENT Laws relating to broadcasting also apply to the Internet. not their legal adviser. • reporting restrictions in cases involving family law.1 LEGAL RESPONSIBILITY INTRODUCTION The most important obligations of SBS broadcasters. The Legal section of the SBS Intranet gives background information about many of the key legal issues facing SBS employees.g. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 8/35 . • contempt. secret recordings of private conversations. pictures. Legal training can be arranged if a specific need is identified in the workplace.3 3. journalists and program makers under various State and Commonwealth laws relate to: • copyright (including plagiarism).e. 3. Where the legal advice is that SBS would be at high risk if particular material were broadcast (i. text. video) that SBS does not own should be cleared in advance for use on the Internet. Never assume that copyright owners of material on Internet sites have waived their rights simply by publishing material on the Internet. All third party material (e. graphics.2 TRAINING AND INFORMATION SBS provides regular training on these and other legal issues. The SBS Corporate Counsel is available around the clock. 3.g. • privacy. • defamation.3 UPWARD REFERRAL When there is any doubt as to whether or not a particular action is lawful (e. there is a low prospect of successfully defending subsequent legal action). However. decisions to publish legally contentious material must be made on proper consideration of legal advice. if necessary in consultation with SBS Legal. 3. as the cost of legal action and damages can be high. the broadcast of part of a program). audio. Enquiries about specific broadcasts should be directed to SBS Legal. Employees involved in online content activities should be mindful of legal and editorial issues relating to the use of that material (see also Guideline 2. and • discrimination and racial vilification. All employees should ensure they are properly informed. The final editorial decision on whether to broadcast. or in what manner. regardless of other considerations the material should not go to air until the matter has been referred to at least a division director or delegate. children and sexual assault. upward referral applies. Our online services are subject to the laws of any country where they are accessed and if we break these laws we may be legally liable. rests with editorial staff.

All employees are required to follow the SBS Code of Conduct (Appendix A) which includes a section on ‘Upholding SBS’s Reputation’. It is the responsibility of each person. Such relationships. 4. an SBS program. will often identify more easily with some sections of their audiences than others. or may be affected by. both actual and perceived. or political viewpoint or party. Potential conflict of interest situations include: • performing work for an outside organisation. • personal use of SBS premises. 4.3 Upward Referral). as a result. Staff in doubt as to whether a conflict exists must seek advice. • the use of family or friends in programs.4 RADIO PRODUCERS There are additional considerations regarding conflict of interest in SBS Radio. commercial. are not acceptable. which could be political. personal or any other kind. 4. to carefully examine their relationships with outside organisations and individuals. Further. stringers and contributors contracted by SBS. including freelance journalists. They must not be seen to be representing any group.1 CONFLICT OF INTEREST INTRODUCTION Conflicts of interest. Where the person with editorial control has a real or perceived financial conflict of interest. post-story announcements for radio. • promoting personal interests or the interests of family or friends.3 FINANCIAL CONFLICT OF INTEREST Anyone who has input into or the ability to influence the editorial content of programs or associated online material must disclose potential and actual financial conflicts of interest to the person with editorial control of the program. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 9/35 . threaten SBS’s capacity to provide an impartial and independent voice in the Australian media. Where permission is given to present or report on a subject in which a person has a financial interest.4 4. facilities or materials for non-SBS purposes. SBS Radio producers have links with the communities they serve and. It is the responsibility of producers to ensure that any affiliations or personal views remain separate from their obligation to observe and advance the programming policies and practices of SBS. Employees must also follow broader guidelines on conflict of interest contained in section 25 of the SBS Accounting Manual (available from your manager or the Finance division). In many cases only the individual concerned will be aware of a potential conflict of interest. particularly when it is in a field related to SBS’s operations. it may be appropriate for that interest to be declared on-air (normally in end credits for television. financial. this separation must be reflected in the content of programs. These ‘Conflict of Interest’ guidelines apply to all SBS employees involved in programming activities. in the context of the programming activities with which they become involved. It is the responsibility of the person to whom the matter is upwardly referred to determine appropriate action. especially when paid. and to notify their manager of any potential conflict. and • having a direct or indirect financial interest in an organisation that is the subject of.2 DEFINITIONS AND SITUATIONS Conflict of interest is where a person who has input into or the ability to influence the editorial content of a program has a direct or indirect involvement or interest in an outside organisation or individual which could compromise or be seen to compromise the editorial integrity of SBS. and a postscript for online material). the matter must be upwardly referred (see Guideline 2. which may include on-air disclosure.

or be sponsored by.2 Editorial independence and corporate support SBS has a limited government appropriation and seeks additional funds to improve its services. and • documentaries and information programs. 5.1 A national broadcaster with a mixed funding base SBS is primarily funded by government appropriations and can supplement its revenue through a range of self-help commercial initiatives. Decisions to produce. Commercial activities must not clash with the SBS Charter or threaten editorial independence and integrity. for example. These are to ensure that: • SBS’s Charter and editorial integrity and independence are not compromised. not on the capacity of a program to attract revenue or other commercial considerations. sponsorship and funding. notably through corporate support.1. commission or acquire programs must be based upon the appropriateness of the program for the SBS schedule. Commercial relationships should be conducted in accordance with the principles of the SBS Charter and section 10(1)(i) of the SBS Act which provides that the pursuit of subsidiary functions must not detract from SBS fulfilling its Charter responsibilities. It believes the best protection of editorial independence and integrity is for SBS to: • publicise and reinforce its commitment to its Charter. and • SBS’s commercial interests are properly and consistently advanced.5 5. Corporate support includes advertising. The first always has priority. Where the advice is that SBS would be at significant risk of compromising editorial independence or breaching the SBS Codes of Practice or the SBS Act. SBS-produced news and current affairs programs (except for sports and weather updates outside the principle news and current affairs programs) cannot accept funding from. There is more flexibility in other program strands. 5. and • be open about commercial activities. any outside organisation. 5.1.1. final decisions should be made by the SBS Managing Director. Our coverage of sport. Any sponsorship arrangement of SBS-produced or -commissioned documentaries must be transparent and include safeguards to ensure that full editorial independence remains with SBS. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 10/35 . The areas where commercial activities have the greatest potential to threaten editorial independence and integrity are: • news and current affairs programs.1.4 SBS Referral Process When there is any doubt as to whether or not a particular commercial relationship may compromise these Guidelines or the editorial independence of SBS. can attract valuable commercial revenue with minimal risk to editorial independence and integrity.3 Responsibilities of employees SBS employees have two responsibilities in commercial dealings with other organisations. SBS can accept a level of corporate support for programming and other activities.1 COMMERCIAL RELATIONSHIPS MAINTAINING EDITORIAL INDEPENDENCE 5.1.5 Mechanisms for maintaining editorial independence and integrity The Board recognises the potential for conflict between programming and commercial objectives. • follow the editorial guidelines which require employees to exercise their judgement in making upward referrals. upward referral applies and advice should also be sought from SBS’s Strategy and Communications division. 5. while maintaining appropriate commercial confidentiality.

If the proposal proceeds.1. background and borders. typography. SBS will provide clear information to audiences about the source and funding of the program.5. This is achieved through the following design principles for webpage construction: • Discreteness: Advertisers’ branding will be defined by clear visual boundaries and other distinguishing design elements such as colour. the proposal must be upwardly referred at least to the respective Director Content (Television and Online) or Director Radio. 5. these are otherwise known as ready-made programs. broadcasting and timing are its prerogative.1 Introduction SBS acquires its programs from a variety of sources. Whether a program is suitable is determined by its content. A program should never be produced or commissioned solely because external funds or other commercial opportunities are available. SBS is not restricted to purchasing arrangements. current affairs and other programming. 5.3 PROGRAM PURCHASES 5. not its source. Where possible. • Regardless of how SBS acquires programming material. the exchange of programs subtitled by SBS for new programs is acceptable. When acquiring programs. are partly or wholly funded by commercial or government organisations. commercial and government. 5. These conditions also apply to SBS accepting offers for free or discounted programs. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 11/35 .2 SCHEDULING PROGRAMS SBS must always follow these principles: • SBS selects programs for their contribution to Charter objectives.7 Additional mechanisms for maintaining editorial independence on SBS Online Advertising and sponsorship content must maintain a structural and visual separation from SBS editorial content. SBS does not exchange advertising time for programming. domestic and overseas.3. 5. the advertiser’s content must appear in a separate browser window. SBS must retain the right to edit ready-made programs to meet editorial requirements under the SBS Act.2 Exchange of Airtime for Programming As a rule. If there appears to be a strong link between program content and the funds provider. 5. For example. When linking to an advertiser’s web pages from an SBS website.3 Programs funded by third parties Some programs which SBS purchases.3.6 Additional mechanisms for maintaining editorial independence on SBS Radio Advertisements and sponsorship announcements on SBS Radio must be clearly identified as such by acoustic and/or vocal means to separate them from news.4 PROGRAM PRODUCTION FUNDING SBS is free to commission independent producers and make funding arrangements for coproductions for any programs which it considers appropriate. 5.1. details of third party funding sources should be obtained.3. • Disclaimer: SBS websites should carry a disclaimer that identifies the interests of advertisers as providing either infrastructure or commercial support for SBS Online and asserts the editorial independence of SBS content creators. SBS Codes of Practice and these Editorial Guidelines. Such arrangements need the approval of the SBS Executive.

devise or bequest which is likely to compromise the editorial independence and integrity of SBS (section 44(4) of the Act notes that this does not preclude SBS from accepting services.SBS accepts that its co-producers will often receive funding and other support towards production from external sources. ‘Natural breaks’ in television programs are described in the SBS guidelines on the ‘Placement of Breaks in SBS Television Programs’ (Guideline 5. SBS requires strict scrutiny of the role of all external funding.2 SBS Commercial Affairs and its agents SBS Commercial Affairs division is responsible for raising revenue from sponsorship and advertising. a news bulletin. Details of funding sources should be obtained from co-producers and proposals referred to the Director Content (Television and Online) or Director Radio. 5.5. The advertisements and announcements must not run in total for more than five minutes in any hour of broadcasting. SBS can raise revenue by broadcasting advertisements and sponsorship announcements. SBS has appointed agents to handle the sale of airtime. SPONSORSHIP AND SBS’S OWN PROMOTIONS 5. facility. The SBS Commercial Affairs division is the contact point for any financial transactions which may directly or indirectly involve advertising and sponsorship or ancillary rights. including the corporate sector. or money from the Commonwealth. or • such investment of funds is likely to influence the editorial independence and integrity of SBS.5 ADVERTISING. facilities.6 below). rather than driven by commercial interests. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 12/35 . gift. section 44(3) of the SBS Act precludes the acceptance of any service. 5. produced or commissioned solely because revenues from sponsorship are available. SBS may make direct program production arrangements with a commercial organisation. In no circumstances will a program be purchased. • the interest of the provider of the funds in the content of any program. ‘Natural breaks’ in radio programs are defined as occurring between discrete units of programming containing matter of a similar nature (e. Corporate funding is acceptable provided that SBS’s editorial independence and integrity is not compromised. This includes the right to edit all content for broadcast on SBS. Whether corporate funding – direct or indirect – and the level of funding is acceptable depends on: • the issues dealt with by the program. and • whether the potential exists to compromise SBS’s editorial independence and integrity. The Director Content (Television and Online) and Director Radio must reject any proposal to produce or commission a documentary or fact based entertainment if: • the investor has a commercial interest in the content of the program. Corporate funding can therefore be both direct and indirect. states or territories or their agencies).3 Sponsorship Program sponsorship is a form of advertising which creates an association between the program and the sponsor.g. The Act provides that SBS may only broadcast advertisements sponsorship announcements before or after programs or during natural breaks. However.5. irrespective of commercial deals entered into by external producers. SBS must always retain the right to ensure that the material it broadcasts is editorially justified.5. SBS allows other organisations to sponsor programs. a feature or a talkback session).1 Introduction Under Section 45 of the SBS Act. 5. Programs with content that is directly connected to the source of funding or sponsorship have the potential to compromise SBS’s editorial independence and integrity.

Any sponsorship arrangement of SBS-produced or -commissioned documentaries or information programs must be transparent and include safeguards to ensure that full editorial independence remains with SBS. and dependent upon client agreement. ‘This program is/was sponsored by…’) • for Radio. Where feasible and cost-efficient. No SBS Radio employee will be compelled to participate or be pressured in any way into participating in the development or production of advertisements or sponsorship announcements.4 Contractual arrangements and conflict of interests Only those employed within or contracted by the Commercial Affairs division may negotiate with potential clients for the sale.5. The exception is in payment for the translation and voice production of advertisements or sponsorship announcements arranged by SBS.5. SBS acknowledges the sponsor of the segment through a voiceover at the beginning and end of the program. SBS should be advised by external producers and distributors of all instances where advertising or sponsorship has been relied upon for the production of a program. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 13/35 .5 Quality and standards SBS retains the right to refuse to broadcast any advertisement or sponsorship announcement which fails to meet its quality standards. production or broadcasting of advertising or sponsorship within SBS programs. SBS employees must disclose any interests they or any member of their family have in the supply of any goods or services advertised on SBS or any other potential conflicts of interest. 5. SBS Radio employees may be engaged for the production of advertisements and sponsorship announcements as arranged by SBS. SBS allows corporate sponsorship in which organisations have their names associated with SBS as a corporation. In practice.Program sponsorship should not be confused with program funding which other organisations may provide to produce a program. SBS employees may not make personal gain for themselves or any member of their family from advertising or sponsorship. • the sponsor’s name may be included in on-air and press promotions. SBS advertisements and sponsorship announcements will be produced in-house. a sponsorship arrangement usually means: • the sponsor’s advertisements are run immediately before and after the program and during natural program breaks. (For example. it is the responsibility of employees to ensure that contractual arrangements with SBS clients are complied with under law. When SBS enters into a contract for the production and/or broadcast of advertisements or sponsorship announcements. Sponsorship is accepted only after a decision has been made to purchase or produce a program. The employee to receive the payment cannot initiate the work. Promotions for SBS-sponsored websites may be broadcast at the end of the program. and • for Television. provided the content of the website being promoted is related to the content of the program. SBS acknowledges the sponsor of the program through a billboard at the beginning and end of the program. Sponsorship of SBS-produced news and current affairs programming (except for sports and weather updates outside the principal news and current affairs programs) is not permitted. Sponsorship of SBS-produced or -commissioned drama or entertainment programming is permitted on the condition that any sponsor’s products are not an unduly significant focus of the program. 5.

The name and logo are valuable assets which may be licensed to third parties. services and activities are permitted. • a requirement that the licensee must do all things required by SBS to ensure the name and logo remain distinctive of SBS and validly registered. these Editorial Guidelines. 5.5. services and activities displaying the SBS name or logo. • appropriate level of editorial control by SBS over content. 5. Any use of the name and logo that has not been expressly authorised by SBS is an infringement of SBS’s rights and is prohibited by law. packaging and advertising. services and activities do not fall within the five minutes of advertising air time allowable per hour providing that SBS is not paid in cash or in kind for the promotional airtime. Director Commercial Affairs.9 Value of the SBS name and logo The SBS logo is registered as a trademark in Australia. or cost centres which may have attracted the revenue. Director Radio. language groups. the aim of which is to protect SBS and its logo. community standards or any other guidelines or legal requirements. The following guidelines must be taken into account in permitting the use of the SBS name and logo by third parties: • Use of the SBS name or logo must be approved by either the SBS Managing Director. • Any benefit to SBS must be taken into consideration.5. Any use of the SBS name or logo must not undermine SBS’s independence or integrity or adversely affect its reputation as a quality broadcaster and good corporate citizen. Goods and services are deemed contentious when their promotion would be inconsistent with the SBS Charter. 5. In exceptional cases. products. employees should contact the Marketing or Commercial Affairs divisions.5. such direct funding must be approved by the SBS Executive. including publicity materials and packaging. Promotions for these types of products.8 Promotion of SBS’s own activities The SBS Act allows SBS to broadcast announcements publicising SBS programs and promoting its products. Corporate Communications Manager or Director Strategy and Communications. and • a requirement that use of the SBS name or logo in the licensee’s own advertising may only occur with the prior written approval of the SBS Managing Director.6 Contentious goods or services SBS Radio should not broadcast advertisements or sponsorship announcements for any contentious goods or services or for those prohibited under state or federal law. Director Content (Television and Online). The agreement must cover: • appropriate quality control by SBS over the licensed goods and services. services and activities. For further guidance on the use of the logo by SBS and third parties.7 Revenue allocation Generally.5. services and activities related to programs that appear on SBS. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 14/35 . References to distributors of these products.5. The use of the SBS name or logo in connection with goods and services indicates that they are endorsed by SBS. advertising and sponsorship revenue will augment SBS’s total budget and will not be paid to the programs. This often includes. • approval rights in relation to the goods and services. and therefore their use must be strictly controlled. Approvals to use the SBS name or logo must be in a written agreement between SBS and the third party. It also includes products. but is not limited to. Codes of Practice.

with a significant break in the continuity of action. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 15/35 .1 Introduction Section 45 of the Special Broadcasting Services Act. and the Federal Chamber of Automotive Industries ‘Voluntary Code of Practice for Motor Vehicle Advertising’.6 PLACEMENT OF BREAKS IN SBS TELEVISION PROGRAMS 5.6.3 Natural breaks in documentaries and information programs A break may be taken when: • there is a change of topic. There is greater flexibility with non-broadcast activities because the specific restrictions in the SBS Act do not apply. where it relates to commercials. 1991 (SBS Act) provides that SBS may broadcast advertisements and sponsorship announcements before or after programs and during natural breaks and that run in total for not more than five minutes in any hour of broadcasting. If the Advertising Standards Board finds that an advertisement contravenes these codes the Advertising Standards Bureau will request the advertiser to withdraw or modify the advertisement in question. • recorded inserts occur in live programs.10 Non-broadcasting activities SBS’s obligation to maintain its independence and integrity applies to non-broadcasting activities – performances. or • there is a change of scene. marketing and publishing activities – as well as to its broadcasting activities. Proposals for use of the SBS logo for other non-broadcasting activities must be referred to the Director Marketing. 5. the ‘Code for Advertising & Marketing Communications to Children’.6. SBS takes account of the ‘Classification and Placement of Commercials and Community Service Announcements’ contained in section 6 of the ‘Commercial Television Industry Code of Practice’ (2004).5. SBS will exercise sensitivity in the placement of advertisements. 5.4 Natural breaks in entertainment programs A break may be taken at the end of an act or at the end of a sequence. All advertisements broadcast by SBS should comply with the Australian Association of National Advertisers (AANA) ‘Advertiser Code of Ethics’. but any practices which undermine the editorial independence and integrity of SBS are unacceptable. 5. SBS will not broadcast advertisements that do not fulfil the requirements for the issuing of a Classification Number (CAD Number) by Free TV Australia’s commercial advice service.6. 5. Use of the logo in programming publicity is a matter for the relevant division director. All advertisements will be clearly distinguished from SBS programming content. As an associate member of Free TV Australia. Decisions about the placement of advertisements in programs will be considered on a caseby-case basis and will have regard to program content and context. All decisions regarding commercial revenue are subject to the overriding principle that the integrity of the SBS Charter and SBS’s editorial independence are paramount and shall not be compromised in any way.6. • there is a change of method or treatment. SBS reserves the exclusive right to determine what is broadcast on SBS services and may reject any advertising or community service announcements.2 Natural breaks in drama and comedy A break may be taken when: • there is an obvious and dramatically significant lapse of time in the action. or • new participants in a discussion program are introduced.5. staged events.

the break pattern of the originating broadcaster may be taken.5 Natural breaks in programs with prizes A break may be taken when one competitor leaves the scene and before a new competitor is introduced.6. SBS will then decide which of these natural breaks will be used to carry advertising based on the five minute per hour limit and other considerations.10 Natural breaks in acquired programs Pre-existing breaks that comply with these Guidelines in programs acquired from overseas suppliers and other sources will be considered to be natural breaks. the following schedule provides an indicative guide for the placement of internal breaks: SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 16/35 .12 Identification of breaks SBS will assess programs to determine where. Acquired programs which do not include pre-existing breaks may be assessed for natural breaks following the definitions in Guidelines 5. 5.6 Natural breaks in music programs A break may normally be taken at the end of a musical composition.6. breaks may be taken during those periods. there are natural breaks in content according to the definitions under Guidelines 5.6. or between the acts of an extended musical work. Where there is no change of competitor.6.11 Natural breaks in relays of overseas broadcasts Where SBS relays a live program feed from an overseas broadcaster.11. a break may occur at the end of one complete round of questions. 5.7 Natural breaks in news and current affairs programs Breaks may be taken between separate reports in news bulletins and program segments in current affairs programs.6. Breaks may also be taken before or after cut-away discussion or background film insert sequences.5.9.6. Within the definitions of natural breaks and the individual context of the program. In sport events where regular pauses in play occur.2 to 5.6.8 Natural breaks in sport Breaks may be taken during periods where viewers do not miss any significant action of the particular sport being televised either live or delayed. • defined by a particular method or treatment. or • a particular topic in an extended interview. In coverage of long continuous events. 5. A program segment may be: • discrete coverage of a particular topic or issue. 5. 5. Breaks may not be taken between segments of a series of pieces usually heard as a continuous performance. • a report from a particular source or location on an issue. for example at half time or between races. 5.6. including viewer experience. and if. 5.6. for example after a resumption of the current placings in a race and before refocusing on a particular section of the race.6. 5. a set.13 Placement of breaks Editorial considerations and the interests of viewer experience will be taken into account when considering the placement of breaks. innings or overs etc.6.2 to 5.6.6.9 Natural breaks in outside broadcasts other than sport Breaks may be taken where the commentator finishes discussing one item in the program and moves to another. breaks may be taken at points where the focus of coverage of the event shifts from one point to another.

program credits are arranged so that the level of assistance is apparent to audiences (credits will normally be in the form of an acknowledgment at the end of a program recognising the contribution made in cash or in kind by a person or party to that program). and may be acknowledged during a program. or images of.7. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 17/35 . 5. Credits: • provide an opportunity for SBS to show its appreciation. SBS will use official names but not unduly emphasise the name of any commercial organisation so as to suggest to audiences that advertisements or sponsorship announcements are being broadcast. When commercial organisations sponsor sporting and other events. services or goods for a program. services and facilities are used is determined by SBS.2 Use of products.4 Program credits Credits will acknowledge financial or other support for a program by reference to the company names and/or logo as determined by SBS.7. competitions and performances Many events.7. there may be deviation from this guide. events. and • make clear to audiences that external assistance has been provided.7. • there is no obligation to structure a broadcast in any way or to present a particular editorial perspective. 5.7 5. Some coverage is purely incidental (e. commercial entities and their products and services occur in the normal course of broadcasting. for example to fit in with a particularly suitable interruption of continuity. coverage will inevitably feature some form of company identification. These will often have official names which include the corporate or product names of the commercial sponsors.g.3 Named activities. sporting competitions and productions involve commercial sponsorship. services and facilities are not used in programs in a way which endorses them. a news story featuring the arrival of a visiting head of state may include coverage of a particular airline).7. offers from commercial or government organisations of free or discounted products. on behalf of SBS and not for private use.5 Acknowledgements and logos Where an organisation has provided information. services and facilities providing the division director has given prior approval and: • the way in which such products. This acknowledgement may take the form of a verbal and/or text acknowledgement or use of the organisation’s logo. 5. performances. 5. Contributions will generally be acknowledged in credits appropriate to the significance of the contribution. It is a matter for SBS to determine where and when the logo will appear in a program or in program credits. services and facilities in program production SBS employees may accept. and • where significant assistance is provided. This will be assessed on a case by case basis applying these Guidelines in relation to natural breaks in accordance with the SBS Act. • such products. this should be acknowledged in program credits.Scheduling Slot Up to 10 minutes 30 minutes 45 minutes 60 minutes Program Length 25 minutes 40 minutes 52 minutes Parts / Breaks No Break 3 Parts / 2 Breaks 3 Parts / 2 Breaks 4 Parts / 3 Breaks Where the interests of viewers would be better served by a different format. LIMITATIONS AND ACKNOWLEDGEMENT Introduction References to. 5.1 CORPORATE SUPPORT: OPPORTUNITIES. thereby allowing them to make up their own minds about possible editorial intrusion. for the purposes of transparency and to make clear to audiences that external assistance has been provided.

the matter must be discussed with the organisers and if necessary referred to the division director. compliance with Internet gaming legislation etc. services and activities and recommendations. Advice should be sought from SBS Legal on the conduct of give-aways or competitions (e.7 Give-aways and competitions SBS can conduct joint promotions with other organisations which might offer free (or tokenpriced) prizes to SBS audiences in on-air or online competitions. flags and posters. Information on the source and nature of the prize can be provided to audiences or users. positive description of the prizes may be used. cultural or community events.6 Signage Signage means advertising messages or logos on banners. However. Organisers of events which SBS wishes to broadcast should be informed of the conditions that apply to advertising and sponsorship announcements on SBS. 5.7. Division directors must approve promotions or competitions involving prizes. In the course of running a competition with prizes. incentives or give-aways. the need for lottery permits or privacy consents. During coverage of the event.g. Endorsements include comparisons between products. some limited. particularly at sporting. this should not be seen as active encouragement of audiences to otherwise purchase or seek out the product or service that constitutes the prize. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 18/35 . Endorsement of the donor’s product or service within programs is not acceptable.).5. cameras must not dwell upon on-site signage. Give-aways and competitions may not be run during news and current affairs programs. If an executive producer considers coverage of an event may contravene these Guidelines.7.

Announcements about meetings of a restricted nature (i. when consideration is accepted for airtime for such announcements. SBS may charge third parties for community announcements.) are not ‘Community Information’ under Code 6 of the Codes of Practice. Announcements promoting community events that are commercial ventures will normally be regarded by SBS as advertising. Generally. WELFARE AND EDUCATIONAL EVENTS The SBS Codes of Practice (Code 6) provide guidance on the kinds of community information SBS is prepared to broadcast. and • there are compassionate grounds for the announcements. With the approval of the Director Radio or his or her nominee. SBS Radio enjoys a special relationship with its audiences and provides a service through the broadcast of community announcements. etc. SBS’s advertising rates will apply. and • concise. Where a language group considers that its audience has special needs and it is appropriate for personal announcements to be broadcast. provided they are: • from bona fide organisations (and if producers are unsure about the credentials of any organisation. such announcements will not be broadcast unless newsworthy. marriages. 6. giving essential details such as time.1 COMMUNITY ANNOUNCEMENTS ON SBS RADIO INTRODUCTION: SOCIAL.e. purpose of event. However. those limited to members of an organisation) can only be broadcast with the approval of station management. The number of times an announcement may be broadcast is at the discretion of the executive producer. authority must be obtained from the Director Radio. they must be counted towards the five minute per hour limit on advertising. Radiothons must be approved in advance by the Director Radio. The length and form of the announcements is a matter for SBS.6 6. 6. without charging for airtime.2 FUNDRAISING Announcements may be broadcast at no cost for appeals by a charity registered in Australia. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 19/35 . deaths. organisation or product in which they or members of their family have a financial interest. CULTURAL. including government information campaigns. listeners may be asked to donate funds or services for such fundraising. • the reliability of the information is guaranteed.3 PERSONAL ANNOUNCEMENTS Personal announcements (births. welfare or educational nature. In no circumstances must producers promote on-air any function. upward referral applies). secretary or office-holder of the organisation. taking into account: • the desirability of broadcasting a variety of announcements. ticket availability and cost. • the quality and effectiveness of a program will be affected by the announcements. cultural. who will consider whether: • there are other ways in which the information can be conveyed to the community. and • the need to give equity of access to different sectors of the community. organising group. • supplied in writing on letterhead signed by the president. venue. SBS Radio may broadcast announcements about community events of a social. Station management must ensure that all fundraising promoted by SBS Radio complies with relevant state and federal laws.

SBS will not broadcast political matter (i.4 GOVERNMENT INFORMATION CAMPAIGNS SBS has an obligation to assist in the provision of settlement and other information to community audiences. Material broadcast as part of such campaigns will carry an acknowledgement of the originating government body.e. which aims to ensure maximum penetration of target audiences with a minimum disruption to language programs. SBS receives payment for producing and/or broadcasting such announcements. 6. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 20/35 . matter that promotes a registered political party or lobbies for a change in legislation) as community information.1 of the Codes of Practice. will be agreed between SBS and the originating organisation. SBS Radio enters into agreements with government departments and instrumentalities for the broadcast of announcements about various campaigns and services. As noted in Code 6. A placement strategy. Producers must broadcast announcements at the agreed times to ensure the effective communication of the information.Announcements regarding missing persons must not be made without the approval of the Director Radio. Accordingly.

Material in which individuals are identifiable and which may be used to suggest that those individuals endorse or support a particular product or viewpoint may only be authorised with the consent of those individuals. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 21/35 .2 Private use In general. radio or print advertisements should be referred to the Director Radio or the Director Content (Television and Online). A licence agreement must be used. 7.3 Use of SBS program material in advertising Requests for SBS program material for use in television.2 COMMERCIAL AND PRIVATE USE 7. or may be. Except in the case of daily news material covered by reciprocal arrangements between broadcasters. it must be retained for 70 days from the date of the complaint. the material must be kept until the proceedings have finished. These fall into two categories: • requests for use of SBS material for commercial or private use. some SBS programs may be purchased on video or DVD through SBS Commercial Affairs or nominated distributors.1 SUPPLY OF SBS PROGRAM MATERIAL TO THIRD PARTIES INTRODUCTION SBS receives many requests for access to program material. Section 70B of the SBS Act requires SBS to retain copies of all broadcast matter relating to a political subject or current affairs for a period of six weeks from the date of broadcast. or within the three month period.1 Commercial use Any use of SBS program material must be authorised by the relevant division director. legally actionable. 7. However. supply of all SBS news material must go through the SBS News Tape Library (Television) or. that material must be retained until legal advice is received that it is safe to dispose of this material. Director Radio. 7. If SBS is notified that material is required for legal proceedings within the six week or 70 day retention periods. Use of SBS program material in political advertisements is not permitted.2. 7. Producers of programs may give copies of SBS program material to participants in the program for their personal use. Individual SBS employees do not have the right to sell or give away SBS program material. If a complaint is made about the matter. If proceedings have commenced prior to the request. Material requested by the Australian Communications and Media Authority (ACMA) will be provided free. SBS does not provide translations of the programs.2. 7.2.3 CONTENTIOUS MATERIAL Contentious material is material in respect of which legal proceedings have been threatened or commenced or are likely to be commenced against SBS or against a third party. and • requests for material which is. SBS does not provide or sell SBS program material for private use or exhibition.7 7. SBS Commercial Affairs division can provide information about these programs.2.4 Program complaints SBS may provide copies of programs which have been broadcast on SBS Television or SBS Radio (at cost) to persons who have made or intend to make a program complaint.

A form is available from SBS Commercial Affairs division or Public Relations for people making such requests. 7. To answer some requests for SBS program material. it may be helpful to direct people to the website. 7. and • states that they wish to assess whether the material may be actionable against SBS.6 VARIATIONS These policies may be varied in exceptional circumstances such as hardship to the person making the request or prejudice to SBS. This material will be made available at SBS standard rates. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 22/35 . Decisions to vary these policies may only be made by the Managing Director. It explains the reasons that SBS cannot supply many of the broadcast programs and suggestions as to how the program may be obtained from the rights holders.SBS will provide access to persons requesting a copy of program material if the person is referred to in the program and the request is made within the six week or 70 day period and if the person: • can describe the program in a manner which enables it to be easily identified. where assistance to the police will help reduce the risk to public safety. SBS will not provide material for use in legal proceedings to which SBS is not a party unless a subpoena has been issued or the request is made on behalf of both parties to the litigation. Requests for program material by the police will generally require a search warrant or subpoena except in clear cases of public danger. the Director Radio or the Director Content (Television and Online).4 PROGRAM-RELATED MATERIAL ON THE SBS WEBSITE SBS is placing an increasing amount of program-related material on the SBS website. 7.5 REQUESTS FOR NON-SBS PROGRAMMING SBS receives many requests for programming that it has broadcast but for which it does not hold rights of sale or distribution. including audio files and text transcripts for some programs.

3. 8. COMMENTS AND ENQUIRIES INTRODUCTION 8. • determine whether a complaint is upheld or dismissed. • commission translations of complaints and programs as required. SBS treats all complaints equally and fairly in line with the complaints procedures set out below. SBS complaints handling procedures do not apply to any complaint concerning a program which is or becomes the subject of legal proceedings.1 What are formal and informal complaints? A formal complaint is one which alleges that SBS has acted contrary to its Codes of Practice and which meets the requirements of Code 8. The Codes of Practice also set out the role of the Australian and Communications Media Authority (ACMA) in investigating complaints about possible breaches of the Codes of Practice which are not handled to the satisfaction of complainants. • refer to Corporate Counsel all complaints which contain the threat of legal action. from the Strategy and Communications division in relation to the interpretation of the Codes of Practice and Editorial Guidelines.1 Code 8 of the SBS Codes of Practice details SBS’s policies on information requests. SBS acknowledges that it is the right of all audience members to make a complaint. including ensuring that formal complaints are answered courteously and within the required timeframe. 8. Television or Online. • provide training to SBS employees about complaints handling procedures. regardless of the source of the complaint. 8. The complaints handling procedure applies to all complaints received about SBS programming and content. and • liaise with ACMA and other external bodies in relation to program complaints which have been referred for external review. • provide information to the public about SBS’s complaints handling procedures.2 COORDINATION OF COMPLAINTS HANDLING The SBS Ombudsman reports directly to the Managing Director and is independent of all SBS programming divisions.3 COMPLAINTS HANDLING PROCEDURE How SBS deals with a complaint depends on whether it is assessed as a formal or an informal complaint. The role of the SBS Ombudsman is to: • undertake a proper and fair investigation of formal complaints. comments and complaints about SBS programming and content. • assist in ensuring the professionalism and consistency in all formal complaint responses across the organisation.8 HANDLING PROGRAMMING COMPLAINTS. including working with the relevant division. • obtain input. These guidelines set out internal procedures. • maintain a central database of all formal complaints. It is SBS’s responsibility to have in place adequate complaints handling procedures and to dedicate sufficient resources to addressing the concerns of its audience. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 23/35 . SBS must investigate and respond to all formal complaints in line with Code 8. whether on SBS Radio. Employees involved in programming activities must familiarise themselves with the Codes of Practice and Editorial Guidelines.4. • provide reports to the Board on the formal complaints received and any relevant details or progress. as required. Responding to complaints and comments is an opportunity for SBS to engage directly with its audience and to promote SBS programs and content.

The director of the division must inform the SBS Ombudsman of the action to be taken. The SBS Ombudsman will provide the relevant division with the final response.11 sets out how SBS handles informal complaints. a response must be provided within 60 days. at its discretion. The SBS Ombudsman will keep a record of the action taken. if a complaint is complex.5 Action to be taken When a formal complaint is upheld. • providing a timeframe for the investigation to be completed. 8. 8. If there is any doubt about whether a complaint is formal. a letter will be sent to the complainant: • acknowledging receipt of the complaint. The SBS Ombudsman will investigate the complaint and the relevant division will assist by providing necessary background information.3. the action to be taken in response to the finding will be decided by the Managing director and the director of the relevant division.3.3 Investigation by the SBS Ombudsman Once a formal complaint has been received by the SBS Ombudsman. • informing the complainant that the SBS Ombudsman will be responsible for investigating and responding to the complaint. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 24/35 . This will allow adequate consideration at a senior level.3. or • uphold the complaint and advise the complainant of the action to be taken. The SBS Ombudsman will endeavour to provide the complainant with a written response within 30 days of receipt of the complaint.3.3. Guideline 8. In exceptional circumstances (as set out under the SBS Code 8. • broadcasting the correct information.3. the SBS Ombudsman will make a decision to either: • dismiss the complaint and advise the complainant again of their right to refer the matter to ACMA (for Television and Radio programs). consider a request for a complainant’s name to be kept confidential in an internal investigation.4 Official response After investigation of the complaint. Any comments requested by the SBS Ombudsman from a division should be provided as quickly as possible and always within 10 working days of the receipt of the request.All other complaints will be treated as informal complaints.4 below.6 Confidentiality SBS will. apology or retraction on the SBS website. • placing a correction. the complaint will be referred to the Complaints Committee. or • broadcasting an apology for the impact of the breach. 8. • apologising for the impact of the breach. it should be referred to the SBS Ombudsman. See Guideline 8. 8. additional time may be needed and the complainant should be informed of any expected delay. If the relevant division disagrees with the decision of the SBS Ombudsman.10). a translation is required. and • advising the complainant of the circumstances in which they may refer the complaint to ACMA. 8.2 Initial assessment of complaints Once a complaint is received by SBS it will be assessed as either formal or informal by the SBS Ombudsman and entered into the complaints database. or the complaint is referred to the Complaints Committee. The action decided on must occur within a reasonable period of the breach finding. including possible investigation and preparation of a final reply. The action may include the following: • acknowledging that a breach has occurred in a program. In any event.

3.3. usually by the respective producer of the program. The SBS Ombudsman will advise the complainant if there is a substantial delay in reaching a decision. Managing Director or Board members Correspondence addressed to the Chairman. 8. SBS management is responsible for resolving any differences arising from the translations relevant to the substance of the complaint. that person must be provided with a copy of the complaint and be given the opportunity to respond to the relevant division director and the SBS Ombudsman. a particular employee in an alleged contravention of the Codes of Practice.3. either directly or indirectly.3. all relevant material and any recommendations by the SBS Ombudsman prior to upholding or dismissing the complaint. 8.4 COMPLAINTS COMMITTEE 8. 8. SBS management may. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 25/35 . The independent translation will be made available to the broadcast journalist responsible for the first translation.10 Translations of radio programs in languages other than English Where a formal complaint is received regarding an SBS Radio program that was broadcast in a language other than English. one member independent of the division being investigated. Director Content (Television and Online).3. who will be nominated and agreed to by the other members on a complaint-by-complaint basis. Director Radio. When responding to informal complaints. arrange for a translation of the program. where appropriate. 8. 8. The Complaints Committee will review the complaint.3. staff must follow the procedures set out in Guideline 9.4. SBS Ombudsman.3.8 Formal complaints addressed to the Chairman.3.11 How informal complaints are handled Informal complaints are handled under Code 8. If the issue is a serious one and resources are available. a single reply to the organiser is normally sufficient. the SBS Ombudsman or the relevant division may refer a formal complaint to the Complaints Committee for further consideration. an independent second translation may be sought.9 Petitions Where SBS receives a petition (via letter or facsimile).3. The Complaints Committee may request additional information and further investigation of the matter before making its decision.3 Decision The decision of the Complaints Committee will be made by majority opinion and will be the final decision of SBS.13.2 Composition The Complaints Committee is composed of the Managing Director (Chair). Director News and Current Affairs. 8. 8. At management’s discretion. where required.4. and.8.7 Complaints involving individual employees Where a complaint being investigated implicates. Managing Director or Board members that raise a formal complaint must be referred to the SBS Ombudsman and be dealt with in accordance with Guideline 8. individual replies may be appropriate.4.1 Function If necessary. The Complaints Committee will endeavour to finalise the investigation of the complaint within a reasonable time.

where possible. 9. the name of the person. Responses should be calm and informative. or asking the callers to set out the matter in writing where the subject of the call is beyond their knowledge or expertise. • taking a record of the caller’s details and returning the call later if they are too busy to handle the call immediately.2. taking responsibility for ensuring the caller gets through to someone who can address their concerns. • briefly record the caller’s views.3 Employees taking calls Employees to whom calls are directed. clearly informing the caller of the name and position of the person they are being referred to.2 Calls to the switchboard The SBS switchboard receives most calls initially. if required. Managers must ensure that the switchboard is advised of any special directions for handling calls in their area. including: • identifying themselves by name and area. including. should try to help the caller in all reasonable ways.2. • when referring the caller to another employee.2. 9. Employees should avoid protracted conversations or arguments with callers about programming policies and should never admit SBS liability. contact number. Where there are difficulties in writing (for example. 9. date and time. subject of conversation. • refer callers to relevant areas if they require further information or explanation. 9. A record of the conversation should be made. heard or read. and advise your supervisor of the conversation. and • if they are the employee who first receives the call. and • take details so calls can be returned later by the relevant area. or who receive calls directly from members of the public.5 Calls which allege a contravention of the Codes of Practice Where a call appears to allege a contravention of the Codes of Practice.2. Dealing with these calls is an important part of presenting SBS to its audiences. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 26/35 . Where possible. Refer the caller to the Codes of Practice on the SBS website and. terminate the call quickly and politely. If complainants become abusive. Switchboard operators are not expected to enter into detailed discussions about programming. send the caller a copy of the Codes of Practice.9 9.4 Managers’ responsibility Managers in each area are responsible for ensuring that employees are briefed on handling calls about programming matters. 9.2.1 General Most comment about SBS programming is by telephone. they: • provide scheduling and other general information about programming. advise the caller that they should make a formal complaint if they would like the matter investigated and advise them of the process for doing so. illiteracy or a disability) alternative arrangements must be made for formal registration of the complaint which should be referred to the SBS Ombudsman.1 HANDLING CORRESPONDENCE AND FEEDBACK GENERALLY INTRODUCTION This Guideline sets out how to handle correspondence and feedback other than formal complaints. • directing calls to their supervisors.2 TELEPHONE CALLS 9. People who telephone SBS to comment or complain about programs are often agitated or angry about something they have seen.

3 Responding to written correspondence Divisions and programming areas will often be required to provide input and comment for responses from the SBS Ombudsman. Such information must be securely stored and the complainant must be informed of the way the information will be used and any person or body to which SBS would usually disclose the information. Any such correspondence which involves a formal complaint must.3. 9.3.g. the Managing Director).3 9. All correspondence must be in plain English.3. addressing the concerns of the complainant and setting out SBS’s position clearly and concisely. job title.1 WRITTEN CORRESPONDENCE Correspondence about programming addressed to the Chairman. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 27/35 . 9. Correspondence which raises a formal complaint should be handled in accordance with Guideline 8. such as a name. (e. Further advice about the application of the IPPs is available from the Strategy and Communications division. telephone number) the privacy of the individuals concerned must be protected. Chairman or division.2 Correspondence to be brought to the attention of SBS management Management needs to be made be aware. in the original correspondence or in any record of conversations. be referred to the SBS Ombudsman to be dealt with under Guideline 8. at an early stage. of potentially serious issues including those which might require public comment.3. Managing Director or Board members Correspondence addressed to the Chairman. Managing Director. Correspondence containing such issues and any correspondence from members of parliament should be sent immediately to the Managing Director and the Director Strategy and Communications. Where material that could identify the correspondent is recorded (e. The person who signs the reply should indicate on whose behalf they are signing. Responding to complaints also provides SBS with an opportunity to inform our audiences about SBS programs and content.g. restrained and courteous.4 PRIVACY SBS is subject to the Information Privacy Principles (IPP) contained in the federal Privacy Act 1988. and be drafted in a professional manner. 9. Managing Director or to Board members that does not raise a formal complaint will normally be referred to the programming area for either direct reply or comment and input. address. at the same time.9.

and • answering internal and external enquiries about SBS policies and their interpretation.10 10. SBS Editorial Guidelines 2006 (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 28/35 . 10.1 ADVICE ON THE CODES OF PRACTICE AND EDITORIAL GUIDELINES STRATEGY AND COMMUNICATIONS The responsibilities of the Strategy and Communications division include: • developing the Codes of Practice and Editorial Guidelines. • providing advice on the interpretation of the Codes of Practice and Editorial Guidelines. and their application to programs. See Guideline 3 for more information on legal responsibility.2 LEGAL SBS Legal provides advice about programs that raise legal issues.

1 SBS Charter The principal Charter function of SBS is to: provide multilingual and multicultural radio and television services that inform. and ensure all SBS services are delivered in an extremely cost effective and professional manner. 1. Overview 1. SBS Codes of Practice and various programming and policy documents and Editorial Guidelines. As a public broadcaster.1 Standards of Behaviour Employees of SBS are expected to abide by the terms and conditions of employment set by SBS. reflect Australia’s multicultural society. This accountability means that SBS must: • • • maintain the highest standards of integrity. television and online services for all Australians. Refer to 3. and We explore and connect the diverse cultures and perspectives that make up the worlds that we live in. For Whom …for all Australians. and. The full text of the Charter is available in the SBS Act on the SBS website (and in SBS’s Corporate Plan 2007-2012). going places that other broadcasters avoid. multicultural Australia and our diverse worlds. Our Purpose is: • Who we are and what we do SBS leads the exploration of the real. in doing so. SBS employees are expected to observe the requirements set out in this Code of Conduct. SBS Award. 1. SBS is accountable to the Australian people through the federal parliament of Australia.2.2. For most employees this includes any obligations set out in the SBS Certified Agreement. multicultural Australia – contemporary Australia is multicultural and multilingual. Purpose and Values 1. SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 29/35 . educate and entertain all Australians. and We reflect real. and be focussed on producing exceptional quality radio.APPENDIX A SBS CODE OF CONDUCT 1. impartiality and service.2 SBS Charter.2 SBS Purpose SBS’s Purpose outlines how we put our Charter into effect. Breaches of the Code of Conduct. This means: ƒ ƒ ƒ • We are a pioneering broadcaster.

3 SBS Values SBS’s Values articulate how and where we spend our time and resources (our focus). clear and transparent in the way we interact with each other. and Making a difference to Australia through our collective actions. trusting and mutually respectful relationships. and how we engage with each other. and Being fair. This means: Delivering on our commitments. we engage with each other through: • Collaboration and openness. and We are distinctive from other media organisations – there is no other public broadcaster like us. Making a difference.2. This means: ƒ ƒ • ƒ ƒ • ƒ ƒ delivering to and expanding our audiences’ interests. 1. and providing services that are relevant and engaging to our audience.3 SBS Corporate Plan The SBS Corporate Plan outlines: • the strategic priorities of SBS. Curiosity and creativity. At SBS.This means: ƒ ƒ • We are relevant to all Australians and inclusive of a multitude of diverse cultures and perspectives. Honesty. This means: ƒ ƒ • ƒ ƒ ƒ • ƒ ƒ Encouraging open discussion and constructive debate. This means: Taking actions that contribute to a successful SBS. and SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 30/35 . and Pursuing new ideas and imaginative solutions that support our shared direction. This means: Seeking. How We Do It …independently. Professionalism and responsiveness. 1. This means: Fostering honest. and As an organisation we are courageous in what we do. both internally and externally. distinctively and courageously. and Being agile and responsive in making decisions and acting on them. respect and fairness. At SBS. This means: ƒ ƒ ƒ As an organisation we are independent from external pressures to conform or favour. and Upholding the decisions that are made. thinking and delivering beyond convention. and We are uniquely placed as the only broadcaster that can reach all Australians. we focus on: • Commitment to audience. and Working together to grow our enterprise and produce exciting outcomes.

Code of Conduct 2. Please refer to Corporate Plan 2007-2012 for details of SBS’s strategic direction and goals. This includes: • • Not taking advantage of their employment with SBS in a way that may compromise the reputation and integrity of SBS. in the course of their employment. A professional approach includes using appropriate levels of: ƒ ƒ ƒ ƒ ƒ • • skill. 2. 2. and the planning processes implemented to ensure SBS achieves its strategic goals and priorities. uphold and promote the Charter. impartiality. and Being careful not to engage in activities in their private life that could adversely affect the reputation and integrity of SBS. and maintain high standards of work performance. Compliance with these laws is a fundamental requirement of employment at SBS. and from which the employee could receive personal reward. comply with any lawful and reasonable direction given by another SBS employee who has authority to give it. 2. (Section 25 SBS Accounting Manual) SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 31/35 . 1.• • the goals of SBS for the five year period from July 2007 to June 2012.4 Assumptions This Code of Conduct assumes that employees of SBS will observe and uphold relevant Federal and State laws and policy. adopt a professional approach when dealing with other SBS employees and members of the community. remuneration or any other type of advantage as a result of the relationship of their position and that particular matter or dealing”.4 Conflict of Interest “Conflict of interest” can be defined as: “an employee having a direct or indirect involvement or interest in any matter or dealing with an external individual or organisation. Purpose and Values All employees of SBS must. care. respect. and conscientiousness.1 SBS Charter. 2. diligence.3 Upholding SBS’s Reputation SBS employees must not engage in any act that may compromise the reputation and integrity of SBS.2 General Behaviour It is expected that SBS employees will: • • treat other SBS employees and members of the community with honesty. courtesy and sensitivity. Purpose and Values of SBS. and fairness.

Managers and/or employees must consider: • • • the capacity of the employee to influence the dealings SBS may have with a third party. 2. In respect of disclosure. and the extent to which the other interests/ employment may conflict with their responsibilities and obligations as an employee of SBS. involvement with political parties and groups. It is impossible to formulate an exhaustive set of guidelines regarding what constitutes conflict of interest. Bullying and Discrimination SBS’s Elimination of Workplace Harassment policy outlines SBS’s commitment to providing a workplace that is free from harassment. SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 32/35 . in determining whether a conflict of interest has arisen or could potentially arise. SBS does not require information on any membership in organisations such as political parties and community groups except where there is a reasonable belief that such membership could give rise to a conflict of interest. Therefore. Conflict of interest may result from: • • • • • • outside employment. In many cases. Some examples of conflict of interest include: • • • • Working for or at any other media organisation or other competitor of SBS (e. involvement with organisations or companies in competition with SBS. SBS expects employees to comply with those guidelines. and the level of personal benefit to the employee or third party that may result from exercising that influence. only the employee concerned will be aware of the potential conflict. financial interest (direct or indirect) in a supplier or SBS contractor. associations with community groups. and holding of company or other directorships. Running for Government office.5 Harassment. Using or misusing any SBS resources for personal. bullying and discrimination. Therefore. Language Services provider). Section 25 of the SBS Accounting Manual outlines procedures that are to be taken to disclose any direct or potential conflicts of interest. employment or other interests. An employee must notify their manager if any of the above situations apply to them. The policy outlines obligations and expectations of employees. supervisors and managers in the prevention and elimination of workplace harassment. it is the employee’s responsibility to notify their manager of any other situation that may result in conflict of interest. Section 4 of the SBS Editorial Guidelines outlines additional guidelines on Conflict of Interest for program makers and content producers. and/or disclose any current or potential conflict of interest to their managers.g. bullying and discrimination.SBS employees must avoid any direct or potential conflict of interest that could compromise SBS. SBS expects program makers and content producers to comply with those guidelines. Having a personal interest in a business that provides services to SBS.

Facilities and Resources SBS employees must use SBS information.6 Gifts and Benefits SBS employees must not improperly use their position. storage and security. property. or use material created in the course of their employment improperly and/or for their own or any other person’s or organisation’s private benefit or gain. 2. email and internet. in relation to “personal information” obtained during the course of their employment at SBS. Email and Internet Usage Policy outlines acceptable use of information technology resources including computers. specific knowledge. The Privacy Act sets out the Information Privacy Principles (IPPs) that govern the way SBS is to manage personal information. processes. software. services or facilities. SBS’s Computer. careful and honest manner. power or authority to gain a benefit or advantage for themselves or others. SBS employees therefore must not accept or give gifts and/or benefits except where it is the custom and practice of a particular culture or organisation with which SBS is dealing. such behaviour is a breach of this Code of Conduct. A copy of the Accounting Manual is available on the SBS intranet (“Finance” site). status. use and disclosure of personal information. SBS employees are subject to certain obligations. SBS expects all employees to comply with this section. databases. access and correction. whether true or not. integrity and security of confidential information for which they are responsible. SBS owns all intellectual property in any material developed and/or made by employees in the performance of their duties or in the course of their employment with SBS. bullying and/or discrimination will be tolerated. In addition to being unlawful. documentation. files. A copy of the Computer.” SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 33/35 . musical compositions. and whether recorded in a material form or not. recordings.8 Privacy and Confidentiality SBS employees have the duty to maintain the confidentiality. facilities or resources to management. about an individual whose identity is apparent. If an employee does accept a gift and/or benefit they must ensure that it is accepted on behalf of SBS. SBS will not tolerate any breach of this policy. SBS employees must be mindful of the public interest and report any misuse of information. This obligation continues during and after employment with SBS.No harassment. facilities and equipment in an efficient. SBS expects employees to comply with this policy.7 Information. and inform their manager. programs. under the IPPs and SBS’s Privacy Policy. trade secrets. 2. etc. or can reasonably be ascertained. Section 26 of the SBS Accounting Manual outlines SBS’s policy and procedures relating to gifts and benefits. Email and Internet Usage Policy is available on the SBS intranet (“Human Resources” site). films. technologies. 2. “Material” includes but is not limited to copyright. from the information or opinion. The Privacy Act 1988 (“the Privacy Act”) governs the collection. The Privacy Act defines “personal information” as: “…information or an opinion. SBS employees may not: • • use SBS’s information.

If the employee is in any doubt. 2. 2. use. 2. in the course of employment with SBS. There may be occasions when public comment on non-SBS matters by an employee acting as a private individual could be detrimental to public perceptions of SBS’s independence. “Public comment” includes views expressed in any forum or media where it might be expected that the comment will spread to the community at large. 2. which risks the health and safety of themselves or others. SBS’s Codes of Practice and Editorial Guidelines provide further guidelines on Privacy for program makers and content producers.SBS employees are required to comply with the Privacy Act.10.1 SBS Matters No SBS employee may make public comment about SBS matters without the authority of the Managing Director or his or her delegate. SBS employees are therefore expected to comply with SBS’s OHS policies and procedures.2 Non-SBS Matters SBS is a publicly funded national broadcaster which must be. SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 34/35 . and be seen to be. particularly when the employee has a high public profile. IPPs and SBS’s Privacy Policy and ensure that any “personal information” obtained by them during the course of their employment is not disclosed inappropriately and/or illegally. In addition to Privacy Act requirements.10 Public Comment. have the right to make public comment and to enter into public debate. See also 2. SBS employees must not engage in any act. there are some occasions where public comment by an SBS employee is inappropriate. Accordingly.10 Public Comment SBS employees. and any other matters relating to SBS’s operations. SBS views this commitment as an individual and collective responsibility of all employees. It is the responsibility of the employee to determine where there is the potential for such a situation to arise and to ensure that their status as a private individual is clearly established before any public comment is made. disclosure or other misuse. and must not interfere with any systems and/or equipment provided for the purposes of health and safety. as members of the community. modification. objective and impartial. employees may have access to confidential and/or commercial-in-confidence information and/or material that must not be disclosed inappropriately. editorial. they should seek advice from their manager. employment and management policy and practices. The Freedom of Information Act 1982 provides a formal mechanism for the lawful disclosure of official information and documents.10. “SBS matters” include programming. and that personal information is secured against loss and unauthorised access.9 Occupational Health and Safety (OHS) SBS is committed to providing a workplace which is safe and without risk to health. SBS makes a distinction between public comment on “SBS matters” and “non SBS matters”. However.

HR – TV and Corporate: (02) 9430 3638 (02) 9430 3637 (02) 9430 3370 SBS Editorial Guidelines 2006 – SBS Code of Conduct (INCORPORATING CONSEQUENTIAL AMENDMENTS MADE 1 JULY 2008) 35/35 . improper or dishonest acts including. embezzlement. 4. 3. Breaches of the Code of Conduct 3. avoiding an obligation and/or causing a loss to another party. but not limited to. theft. Breaches of this code are of serious concern to SBS.2.11 Fraud The term ‘fraud’ is used to describe illegal. Human Resources: Assistant Director. conspiracy. Counselling and Misconduct Procedures and Section 22 of the SBS Accounting Manual.1 What if the code is breached? This code of conduct is provided so that standards of behaviour expected by SBS are clear to all employees. Accordingly. SBS expects employees to comply with this section. you can contact Human Resources on the following numbers: Director. misappropriation. SBS is not required to use a criminal conviction and/or prosecution of fraud as the basis for determining whether an act is fraudulent and/or in breach of this Code of Conduct. extortion. SBS. HR – Radio: Assistant Director. 3. If you require further information. forgery. as a publicly funded broadcaster with responsibility for the appropriate use of taxpayer funds. Section 22 of the SBS Accounting Manual outlines the procedures for controlling fraud and cases of suspected fraud. will not tolerate any acts of fraud perpetrated by an employee or contractor. Any suspected case of fraud will be investigated by the relevant Manager/Supervisor and may be referred to the SBS Board Audit and Finance committee by the Chief Financial Officer. unethical. Any internal investigation should be conducted with reference to the SBS Internal Discussion. For practical purposes fraud may be defined as the use of deception with the intention of obtaining an advantage.2 What if I suspect a breach of the Code of Conduct? If you believe another person is breaching the Code of Conduct. concealment of material facts and collusion. deception. Further Information If you are unsure of any aspect of the Code of Conduct you should discuss this with your immediate Supervisor and/or Cost Centre Manager. false representation. corruption. bribery. SBS will refer any acts of fraud or suspected fraud to the police and criminal or civil actions may be taken against employees or contractors who participate in such unlawful acts. an employee who breaches any aspect of the Code of Conduct may be subject to disciplinary proceedings up to and including termination of his/her employment. you should discuss this with your immediate supervisor and/or Cost Centre Manager.

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