Submission on the Draft Editorial Policies of the South African Broadcasting Corporation

By the South African Communist Party

13 June 2003

Contents Page

1. Introduction
   • Purpose
   • Outline
   • Public Meetings
2. The Role of the SABC in Society: SACP Vision
3. Programming
   • Sponsorship of Programmes
   • Religion
   • Africa and the developing world
   • Gender
   • Transparency
4. News, Current Affairs and Information Programming
   • Current Affairs and News
   • Business and Economic Analysis
   • Labour Coverage
5. Local Content and Language Policy
6. Editorial Independence and Complaints
7. Funding the Mandate
8. Corporate Governance, Labour Relations and Public Accountability
9. Conclusion and List of References

1. INTRODUCTION

The South African Communist Party (SACP) welcomes this opportunity to comment on the Draft Editorial Policies (DEPs) published by the South African Broadcasting Corporation in terms of the Broadcasting Act.

The publication of the DEPs and call for public comment is an important opportunity for the broader South African public, the majority of which is poor and working people.

The DEPs process provides an opportunity to reflect on the post-apartheid transformation, restructuring and commercialisation of the SABC over the last 9 years ? a period corresponding with the first 9 years of a democratic South Africa. The DEPs process must be informed by a full understanding of the successes and failures at maintaining values espoused in the DEP.

Purpose

Given that the SABC has been disproportionately influenced by well-resourced, albeit unrepresentative pressure groups, the SABC DEPs provide an important platform for a broad cross-section of progressive forces representative of poor and working people to engage with the SABC?s transformation. Specifically, the SACP is committed to an ongoing engagement with the SABC and other stakeholders on the consolidation of the SABC?s mandate and thus the unique role that the SABC should play in broader, social, cultural, economic, political and other matters of national importance. The SACP will also follow up this written submission with meetings and presentations to the SABC Board and Management.

Through this submission, the SACP welcomes and regards the DEPs as an important step forward in ensuring that the SABC plays its role as a public broadcaster which is sensitive to the diverse needs and interests of the broader public.

The DEPs are generally good in intent but the real test will lie in their actual implementation. Through this submission, the SACP therefore is contributing to the development of a template against which to measure the public broadcaster.

In addition, there are a number of glaring gaps in the DEPs and a range of practical problems we note in current SABC practices and programmes. This submission raises concerns and proposals informed by the need for the interests, needs and progressive perspectives of poor and working people to inform and locate the role, and thus general policies and practices, of the SABC.

Outline

The submission starts with an SACP perspective and vision of what the role of the SABC should be in our society. It then makes specific analysis of, comments and proposals on the following as outlined in the DEPs:

• Programming (Sponsorship of Programmes, Religion, Africa and the developing world, Gender and Transparency)
• News, Current Affairs and Information Programming (Current Affairs and News, Business and Economic Analysis and Labour Coverage)
• Local Content and Language Policy
• Editorial Independence and Complaints

The submission then concludes with brief notes and proposals on SABC Funding, Corporate Governance, Labour Relations and Public Accountability.

Public Meetings on the Editorial Policies

The SACP welcomes the commitment made by the SABC to call public meetings which will receive comments and inputs on the DEPs and other related matters concerning the SABC.

These public meetings, in our view, will make it possible for hundreds of representatives of the broader South African public to air publicly their views on the role of the SABC and the content of the DEPs. Such public meetings will also be an important opportunity for the SABC Board and Management to interact with the public. The public meetings would also lay the basis for a thoroughgoing mechanism for public input into, and engagement with the SABC.

However, the potential and scope of these public meetings may be limited if the SABC does not consciously target and mobilise large and important sections of our society which do not have resources, means and power to air and promote their views, interests, comments and inputs on the SABC in general and the DEPs in particular. The SACP therefore calls on the SABC to ensure the following:

• Publication and distribution of the DEPs and/or summaries in all official languages
• Special radio and TV programmes to introduce and conduct a public (phone-in) discussion of the DEPs before, during and immediately after the public meetings
• Decentralisation of the venues/location of the public meetings to include smaller towns in order to allow the maximum possible access by the general public
• Targeting, mobilisation and empowerment of specific sectors in order that they make considered inputs to the public meetings ? the specific sectors could include youth, women, rural organisations, community based organisations, people living with disabilities, people living with HIV/AIDS, the elderly, organised workers and trade unions, children, farm workers and communities of faith (this is not an exhaustive and exclusive list).

2. THE ROLE OF THE SABC IN SOCIETY: SACP VISION

The role of the SABC must be informed by the context of broader South African media. South Africa?s history of colonialism, capitalism and apartheid permeates all facets of society including the media. In other words, the role of the SABC and thus the DEPs must take into account a range of factors which characterise and inform South African media. Key amongst these factors are ownership and control of SA media, the role of media in a democratic SA, and what determines media content and coverage.

The SACP does not accept the view that the media is a neutral arbiter and analyst of society seemingly above and outside of ongoing contestation and struggles. In the view of the SACP, the ownership and control of South African media is not immune from the influence of those who command financial and other resources.

The legacy of colonialism, capitalism and apartheid is reflected not only in the patterns of media ownership and control, including imbalances within the newsrooms, but also in the lack of access to alternative media platforms and institutions for the majority of South Africans who are, in fact, overwhelmingly economically disempowered as the unemployed poor or exploited workers.

The overall impact of the above is the unrepresentative established view and story line that dominates South African media.

The SACP moves from the premise that communications play a major role in deepening our democracy, promoting a culture of human rights and the transformation of our country. As South Africa, like the rest of the world, is engulfed in an information society, it is critical that the overwhelming majority of our people have access to the widest range of information and opinion in order to participate effectively in an increasingly integrated world at local, national and international levels.

The challenge of thoroughgoing democratic transformation of South African society as it affects the media in general, and the public broadcaster in particular, is therefore a challenge to ensure that, ultimately, all interests, sectors and schools of thought are adequately and proportionately catered for by the public broadcaster. The SABC plays a critical role in shaping opinions and building societal values, including the moral fibre of our society, socio-economic transformation and the building of a united, patriotic nation. All these mean that the SABC is and must remain a public and social good.

The SABC cannot, therefore, pretend to be above these race, class and gender realities and contestation. In order for the SABC to belong to the South African public and reflect its identity and diverse nature, then the SABC should mirror the society it reports about. It cannot be detached from the transformation agenda which seeks to address race, gender and class inequalities we inherit from apartheid.

This challenge requires meaningful and thoroughgoing redress of the exclusion and marginalisation of groups and interests from access to the SABC as a public broadcaster. The SABC must contribute to media diversification by ensuring that previously marginalised interests and sectors have affordable access to a range of views and information fully reflective of our society.

Therefore, a critical task is the comprehensive transformation of the public broadcaster to reflect the diversity of our people and the needs of the democratic society. Related to this is the central question of how does the SABC align its goals, policies and practices with our country?s developmental objectives as enshrined in our country?s constitution and the Reconstruction and Development Programme (RDP) without becoming a state broadcaster. As the SACP we argue, without fear of contradiction, that the SABC?s goals, aims and objectives must be accountable and answerable to the developmental and constitutional vision, aims, objectives, principles and values enshrined in the RDP. But this is not the same as state control of the public broadcaster.

3. PROGRAMMING

3.1 Sponsorship of Programmes

The DEPs commit the SABC to comply with the ICASA regulations on programme sponsorship. The ICASA regulations emphasise the following:

• Editorial Control must remain with the broadcaster
• The depiction of the name or logo of the programme sponsor, during the sponsored programme, must be subordinate to the content of the programme
• The programme sponsor?s association with the programme must be stated clearly, both before and after the programme

However, the SABC violates these ICASA regulations in its daily practice and the DEPs do not address this reality. The SABC is dominated by a dangerous "lotto mentality", a "zama-zama, dog-eat-dog" morality through shows such as the Sanlam Money Game. To substantiate these arguments, we use the two examples of the 2000 Nedbank Series on Asian Economies screened on SABC 3 in October 2000 and the Wena Nemali Yakho Programme running currently on Umhlobo Wenene Radio Station every Wednesday evening (during the hour between 20h00 and 21h00).

Nedbank Series on Asian Economies

During October 2000, SABC 3 screened a Nedbank-sponsored series called ?Secrets of Success?. The series was devoted to case studies of Asian economic successes. The first of the series was devoted to the development of India's information and technology capacity.

The general idea of such a series is to be applauded. We need, as a country, to introduce into the public debate an understanding of the remarkable achievements in growth and development that have been notched up by a number of Asian societies. Sadly, this potentially useful opportunity was abused by the ideological myopia of the bank-roller, Nedbank and the susceptibility of the SABC to private commercial interests instead of it playing its public service and developmental role.

The programme devoted to India was superficial in the extreme. It noted the remarkable success that India has achieved in producing thousands of exportable software programmers, and in attracting some big corporations, notably British Airways, to base IT related operations in India. The programme, in passing, noted the vast inequalities and deep-seated poverty in India, and somehow expressed the cheery sentiment that IT successes would trickle-down to solve everything. Out of all of this, the programme contrived to draw a lesson, which, we were told, is that government must stay out of business, and leave the economy to the private sector.

No mention was made of India's very regulated stock and financial markets a factor which at least some scholars have cited as the prime reason why the Indian economy escaped the Asian contagion of the late 1990s. No mention was made of the extensive public sector in India notably the national railway system. The extensive women-led co-operative movement which is transforming and building sustainable livelihoods in many parts of India was not mentioned.

Nedbank, pursuing its own profit-seeking agenda, was deliberately manipulating public opinion, and deliberately abusing public broadcasting time. And the public broadcaster allowed this without even space for a debate after every episode. As a matter of fact, the SACP released a statement and sent a complaint to the SABC which were not responded to.

Wena Nemali Yakho

The "Wena Nemali Yakho" ("You and Your Money") programme is sponsored by People?s Bank and Old Mutual under the pretext of providing education and information on financial literacy. As a matter of routine, after an initial general exposition of general financial literacy, the programme becomes an hour-long advertisement of a range products and services of People?s Bank and Old Mutual. Instead of the sponsor logo and products being subordinate to the content of the programme, the "Wena Nemali Yakho" violates and turns the ICASA regulations around by promoting the advertisement of specific financial products People?s Bank and Old Mutual. In effect, this subordinates the public interest in having access to information and education on financial literacy and options.

A financial literacy programme is an important service and it must look at the whole spectrum of financial, savings and other tools that ordinary South Africans can use to improve their financial literacy and position. These include local and community owned burial societies, savings and credit co-operatives, community trusts, co-operative shops owned by communities, and so on. However, the "Wena Nemali Yakho" programme just falls victim to the established view and story line that there is only one option on financial matters (the dominant option represented by private commercial banks and other financial businesses) instead of various alternatives which, in the view of the SACP, are more appropriate to our conditions.

The programme does not address inhumane evictions and discrimination against women, low-income areas and people living with HIV/AIDS practiced by financial institutions. This should be the core content of the programme.

Enterprise Zone

Enterprise Zone is an important SABC education programme educating the public about business development. However, it narrowly focuses on individual business as if there are no other alternatives such as co-operatives, community trusts, workers? buyout of failing companies, and so on.

Implications and Remedies

As South Africans we must be vigilant about the arrogant agenda of those with sufficient financial and other resources to sponsor programmes in the SABC. It is our money they are using whether to make skewed, anti-development investments or, as in the Nedbank series, to manipulate public debate.

In this regard, the SACP calls on the SABC to address the above concerns by doing the following:

• A review of all sponsored programmes in the SABC, in particular SABC radio, with the intention to ensure compliance with the ICASA regulations ? the review must be completed by March 2004 and must include:

  • Mechanisms to ensure checks and balances such as balancing of the sponsored programme with alternatives or subjecting the sponsored programme to a debate, and so on
  • A review of the impact and extent of commercial influence and advertisements in children?s programmes

• Revision of all educational programmes on business, including Enterprise Zone, in order that they include community development, sustainable livelihoods and collective forms of business ownership and structure such as co-operatives, community trusts, and so on. This must be done by the end of 2003.

3.2 Religion

The DEPs state that "The SABC?s programming should reflect a mix of South Africa?s major religions, while allowing expressions for those religions that do not have an extensive following". The SACP welcomes this as an important principle. However, it is not adequate. It does not take into full account the logic and implication of the freedom of religion provision in our country?s constitution. In the view of the SACP, freedom of religion also means the freedom of all South Africans to believe or not to believe in religion. The freedom of religion provision is based on the constitutionally enshrined separation of religion and the state, and the recognition that African traditional beliefs and religions and minority religions such as Islam, Judaism, Hinduism, Buddhism and others were ignored and undermined during the apartheid dispensation.

Current SABC religious programmes are dominated by crusading evangelisation aspects of which promotes gender oppression. This exclusive crusading evangelisation effectively blurs the constitutionally enshrined separation of the state and religion. This is not to say that the SABC is or must become state broadcaster. In the view of the SACP, the separation of state and religion applies to the SABC as well since it is a statutory body accountable to parliament and thus the constitution which enshrines freedom of religion.

To cast away any doubts, the SACP reaffirms its support and respect for the freedom of religion of all South Africans. As a matter of fact, the overwhelming majority of SACP members are religious and many of our meetings open and close with religious prayers.

Remedies

The SACP calls on the SABC to address these problems by doing the following:

• To review existing religious programmes with the intention to promote comparative education and analysis of religions and other forms of belief and non-belief, and tolerance of different religious beliefs and non-beliefs rather than exclusive crusading evangelisation
• The public review of religious broadcasting in order to strike a balance between the constitutional freedom of religion and evangelisation
• To ensure that African traditional religions, Islam, Judaism Hinduism, Buddhism and other minority religions get increased exposure and objective analysis in the SABC.

3.3 Africa and the developing world

The SABC brands itself as based on the theme of African Renaissance and has established broadcasting services focusing on Africa. Unfortunately, this is not enough as this focus is heavily influenced by downloads from Western capitals. The SABC needs to cultivate journalists who can actually cover Africa from African perspectives.

The SACP is disappointed that 9 years into our democracy, the SABC is still dominated by cheap and low quality programmes imported from the United States of America and Britain as if there are no programmes from fellow Africans, Asia, Latin America, the Middle East, Eastern Europe, the Pacific, the Caribbean and other regions of the world. Current SABC programmes are still biased in favour of Western knowledge at the expense of indigenous knowledge, developing world knowledge and alternative history.

The SACP calls on the SABC to:

• significantly increase the share of programmes from outside the USA and Britain by specifically focusing on African programmes first and also other regions of the world
• increase broadcast time for SABC Africa
• consolidate its work and co-operation with other broadcasters within the African continent
• increase coverage of indigenous knowledge, developing world knowledge and alternative history

3.4 Gender

The DEPs commit the SABC not to cover programmes which degrade and undermine women, and promote sexism and gender inequality. Yet almost every SABC Africa-language radio station has drama programmes which promote violence against women and which depict women as witches, etc.

The SABC also falls victim of not covering women sufficiently and reinforcing gender stereotypes. The experiences, faces and voices of women are not adequately broadcasted by the SABC. The SABC continues to project women as welfare cases, passive recipients, vulnerable groups needing protection and as physical objects (beauty queens and models). All these images ignore women as independent, intellectual beings, as leaders, decision-makers, academics, active agents for change, and so on. Many SABC programmes do not portray men as care-takers. Instead men are more often represented in roles which reinforce gender oppression and stereotypes.

Remedies

The SACP calls on the SABC to address the above by:

• Immediately reviewing and canceling all radio dramas which reinforce gender oppression and stereotypes
• Starting a dialogue during 2003 on gender and the SABC in order to undertake a critical analysis of current treatment of gender issues in the SABC and to develop a more comprehensive approach and programme to gender by the SABC.

3.5 Transparency

The SACP believes that policy-making and decision-making on SABC programming must be an open and transparent process. This is not currently the case and the DEPs do not address this aspect. The SACP calls on the SABC to develop mechanisms for public input, comment, enquiry and monitoring of the framework which informs programming and to ensure public scrutiny of practical implementation of the framework.

4. NEWS, CURRENT AFFAIRS AND INFORMATION PROGRAMMING

The text of what the DEPs say on News, Current Affairs and Information Programming is generally good and must be welcomed. However, the intention needs to be urgently met with a fundamental change to current practice.

Current Affairs and News

Compared to the need for information and empowerment of ordinary people to be aware of, and to take part in important public debates, the SABC?s African language radio stations (which cater mostly for black people) do not provide sufficient resources and time to programmes for current affairs. To illustrate this case we contrast existing current affairs programmes in Umhlobo Wenene (Xhosa with 3.06 million listeners) and SAFM (English with 0,287 million listeners).

SAFM has the following major current affairs programmes (there are several other current affairs programmes on SAFM):

• AM Live ? daily from 05h30 to 08h00
• After 8 debate ? daily from 08h00 to 09h00
• Vuyo Mbuli show ? daily from 09h00 to 12h00
• PM Live ? daily from 16h00 to 18h00
• World Radio Network ? daily from 00h00 to 05h00

In other words, SAFM has a minimum of 67 hours a week on current affairs. Contrary to this, Umhlobo Wenene provides only 15 hours for current affairs programmes. The only current affairs programmes of Umhlobo Wenene are:

• Laphum? ikhwezi ? daily from 05h30 to 06h30
• Apha Naphaya ? daily from 12h00 to 13h00 and from 18h00 to 19h00

The 15 hours for current affairs programmes in Umhlobo Wenene are typical of the broadcast time allocated for current affairs in the 8 other African-language SABC radio stations. Taken together, the African-language radio stations reach out to more than 15 million listeners.

This demonstration means that 0,287 million South Africans have thorough and high quality information on current affairs whilst at least 15 million South Africans receive brief snippets on important and complex national debates which are so central to the improvement of their lives. The 0,287 million listeners of SAFM are mainly middle class with good professions, education and access to financial and material resources. In contrast, the 15 million listeners of African-language listeners are overwhelmingly poor, without resources, without adequate social services, financial and material resources.

In other words, the existing time allocations for current affairs programmes in African-language stations undermines the intellectual integrity of the majority of South Africans. In effect, this practice is a gross violation of the human rights of the majority of South Africans, in particular women, as they are denied their right to communication and information. This also reinforces the rural-urban divide and apartheid geography.

The SACP calls on the SACP to urgently address this situation by doing the following:

• Review of all current affairs programmes in African-language radio stations with the intention to ensure that the time allocation for broadcasting of current affairs programmes in these radio stations is increased by at least 50% by the end of 2004
• Consolidation and improvement of talkshows and debates on current affairs programmes in African language programmes
• News bulletins on international events should not depend exclusively on western sources such as CNN, SKY or BBC. Other alternative sources must be considered

Business and Economic Analysis

In general, the SABC, like the rest of South African media, relies almost exclusively on white male corporate economists, at the expense of a diversity of views and standpoints, for analysing the South African economic situation. Very rarely, are alternative economists and analysts expressing the views and interests of poor people, women, workers, youth, people in rural areas, and other marginalised sections of society. The daily 'economic indicators' used by the SABC say nothing about poverty indicators, development and service delivery indicators, inequality indicators, the gender impact of the economy, retrenchments, job creation, the impact of the social wage on the economy, the impact of the investment strike by South African private capital on the economy, and so on. In other words, SABC business and economic analysis is purely and exclusively from the standpoint of private corporate interests as if the SABC is not a public broadcaster with a public service mandate to deliver certain services to a South Africa with the majority of its people excluded from the mainstream of the economy.

Illustration - just after the 07h00 news bulletin on 11 June 2003, the business report in Morning Live (SABC 2) reported, with a strong hint of excitement and enticement, that millionaires in the world have actually increased their wealth despite the bad state of the global economy. The requirement and necessity of objective analysis, needed from the SABC as a public broadcaster, would have dictated that the SABC must balance and critique this report with an analysis of the impact of this growth in wealth for a few on overall economies, workers, poor people and developing countries. The Morning Live business report did not do this.

In line with the DEPs, the SACP calls on the SABC to address these problems in its economic and business analysis by doing the following:

• Developing and implementing alternative and developmental economic indicators and analysis as an integral part of its business and economic analysis by the end of 2003
• Diversification of economic and business analysis and coverage
• Development and utilisation of a wide range of new and alternative economic commentators and analysts. As far as possible the SABC must ensure that a diversity of views and opinions are represented on the analysis of politics, economy, religion, education, etc. The opinion of ?experts? who are invited to appear on radio and TV programmes must not be given more credence than it deserves, and the public must be allowed debate their viewpoints during the show.

These measures will ensure that the South African public receives relevant and diverse developmental economic analysis. These measures would be in line with the SABC mandate and the DEPs.

Labour Coverage

The COSATU submission on the DEPs makes very useful and critical points on how the SABC covers labour issues. The SACP fully endorses these points.

In addition, the SACP notes that the SABC has not developed a substantial cadre of journalists who cover and analyse labour news. The recently introduced SABC Labour Slot is a welcome step forward but it must not end up with the marginalisation and ghettoisation of labour issues just to this slot.

Secondly, SABC coverage of labour issues is the most sinister aspect of how the SABC, even though it is a public broadcaster, actually buys into the established view and story line dominant in privately owned media. Recently, Duncan Innes (a labour law consultant) was quoted on SAFM saying that "despite the Growth and Development Summit, COSATU must still learn that economic growth will not come so long as there is no labour market flexibility" (Interview on PM Live, SAFM, 10 June 2003) and the SAFM interviewer moved on without debating and questioning what Innes said as if this was the truth.

The Duncan Innes case demonstrates, once more, how the SABC just uncritically imbibes and repeats the established view and story-line (an already completed script in service of the private corporate?s voice) as if it is not in a developing country with an overwhelming majority of its people being the unemployed poor and exploited workers. The established view and story line portrays the gains of organised workers (e.g. worker friendly labour laws) as the principal cause of unemployment and poverty. In terms of this story line, organised workers are also held responsible for the very same retrenchments they have been victims of. Even more sinister in these attacks have been attempts to project working class struggles as being directly at the expense of the poor. Clearly, the SABC falls victim to this already completed script.

The SACP calls on the SABC to address these problems by doing the following:

• Greater and better-resourced coverage of labour issues
• The establishment of a full and comprehensive SABC labour desk
• A daily focus on labour news in all major news bulletins
• The expansion of the new SABC Labour Slot into a dedicated and substantial weekly current affairs labour programme in SABC television and radio

5. LOCAL CONTENT AND LANGUAGE

Local Content

The commercialisation of the SABC has impacted negatively on the promotion of local content by the SABC. It has become simply too easy for a commercialised SABC to fill up airtime with cheap and low quality American and British programmes.

The SABC cannot continue hiding behind the argument that imported programmes are cheaper than local production as if the programmes currently imported by the SABC have real and meaningful relevance to South Africans. This SABC argument undermines the development of high-quality local content programming, reinforces the urban bias evident in much of SABC?s programming, and undermines the development and increased utilisation of African languages in the public broadcaster.

The outsourcing of internal production capacity by the SABC has a negative impact on the growth and promotion of local content and on the affordability of local content. This outsourcing has also led to a situation where more than 2000 external (contract) producers produce SABC programmes. This must be a nightmare to manage but also raises questions of how open and transparent the commissioning of programmes is. On what criteria are external or in-house producers chosen?

In addition to other imperatives of nation-building, promotion of SA culture and music, and so on, the promotion of local content can have a positive impact on job creation through the SABC playing its role in building a thriving and diverse local production industry which produces high quality programmes.

The SACP calls on the SABC to address the above by:

• Increasing its commissioning of programmes and drama which is in line with new constitutional dispensation.
• Engaging the relevant SETA (Sector Education and Training Authority) to support training and other programmes to make the increased production of local content possible.
• Reviewing the outsourcing of internal production with the intention to build SABC internal capacity for production
• Set local content targets which are higher than ICASA targets
• Set quality standards for importation of foreign programmes
• Publishing for public comment new criteria for commissioning of programmes
• Publishing for public comment a cost-analysis of internal production versus outsourced production

Language Policy

The SACP fully endorses the section of the COSATU submission which deals with language policy of the SABC. In addition, the SACP calls on the SABC to review its emphasis on resources, as this will perpetuate marginalisation of several African languages.

6. EDITORIAL INDEPENDENCE AND COMPLAINTS

Within objective limits, the SACP believes that the SABC must promote sufficient and genuine editorial independence.

The SACP is extremely concerned at the recommendations in the DEPs concerning upward referral, upward approval of controversial news, mandatory referral, and the proposal that final authority and control over news programmes commissioned and broadcast by the SABC must vested upon the chief executive.

These recommendations raise the spectre of an invisible censor not accountable to a public process who will unilaterally decide on what is controversial. This also blurs the necessary distinction between management roles and editorial roles. This also opens the SABC to undue external commercial, political, religious and other influences.

The DEPs do not state clearly what criteria the SABC intends using to determine what is controversial and there is no clear definition of 'extraordinary matter' or 'public response implication' and yet these are the justifications for upward and mandatory referral proposals. The SACP is also concerned that the DEPs merely state the intention to "seeking balance by presenting relevant views on matters of importance": without defining 'matters of importance'.

The SACP calls on the SABC to review and withdraw these provisions from the DEPs and to explore the development of relevant policies which address the SABC justifications for the referral proposals without undermining sufficient editorial independence of editorial staff.

Regarding compliance, the SACP recommends that the Broadcast Compliance Team proposed in the DEPs must include members of the public (appointed through a public participation process), and that the adjudication process is transparent. The office of Broadcast Compliance should ensure that complaints received and decisions taken are made available to the public.

7. FUNDING THE MANDATE

The issues addressed in this submission will not be addressed without addressing SABC funding.

The SACP believes that the SABC, as a public broadcaster, must not be driven by the logic of the private market. There is a contradiction of meeting a public mandate via private sources of income as this undermines the public mandate. If there is reduced public funding for the public broadcaster, then it ceases to be a public broadcaster. Any gradual reduction of public funding will lead the public broadcaster to focus on commercially viable activities at the expense of the SABC?s public service mandates.

For example, research shows that SABC reliance on adspend is 77%. In essence, this means that SABC is privatised and commercial broadcaster of a special type which accounts to advertisers first and foremost. This has led to pressure to attract higher LSM (living standards measure) viewers at expense of the needs and interests of the majority. In other words, wealthier audiences are therefore prioritised as a result. This also introduces pressure on the SABC to spend more money repositioning itself continually to attract more advertising revenue which may even lead to more instability for its workers and users.

As part of commercialisation there is an increasing use of SABC journalists and deejays reading adverts. This blurs the necessary distinction between public broadcasting and commercial activities. This practice must be reviewed.

Funding the SABC through the TV Licence Fees is inappropriate; the collection process is expensive, and is unlikely to improve given the rise in unemployment levels and low wages for the majority of employed workers. When the poor cannot afford to pay for these licences, they are criminalised. TV License Fees are also a form of regressive taxation which is not linked to employment status and income levels.

The SACP strongly argues for an SABC which is fiercely independent from commercial interests and the logic of the private capitalist market.

The SABC Board and Management must work towards increased public funding of the SABC. Government must move towards establishing a public funded model of the public broadcaster characterised by cross-subsidisation, including parastatal sponsorship of local content and investment from different government departments. In order to reduce dependence on advertising, government must increase its funding of the public broadcaster and must introduce progressive licence fees.

The policy intentions in the DEPs must be matched by the mobilisation of sufficient public resources. This requires that the SABC, government, parliament and the public must review the current framework which informs SABC funding. The SACP will engage all these role-players and other stakeholders towards this review.

8. CORPORATE GOVERNANCE, LABOUR RELATIONS AND PUBLIC ACCOUNTABILITY

Corporate Governance

Also central to the implementation of the DEPs is good and efficient public sector corporate governance. In the view of the SACP, aspects of practices of the SABC management reflect those of a private corporate rather than a public entity. SABC management has succumbed to commercialisation pressures.

It is critical that the senior management of the SABC has a clear sense of public responsibilities and national strategic priorities, and that they grasp the qualitative difference and advantages of a public broadcaster. The tendency for some senior SABC managers to see themselves as under-graduate capitalists, rather than public servants of a special type with their own mandate and long-term commitments is part of a major problem.

Public Accountability

The SACP intends to engage the SABC, government and parliament to ensure that the SABC Board includes labour and community constituencies as it is currently not sufficiently representative. There needs to be constant inter-action with, and monitoring of the SABC by the public. The SACP calls for an annual SABC public review process.

Labour Relations

The SABC must continue to address equity, skills development and improvement of working conditions. Admittedly, the last 9 years have seen the managerial and editorial promotion of black individuals and women in the SABC. This kind of active promotion holds out more transformational possibilities. In principle, the promotion of individuals with an organic connection to poor working class communities can help (and in practice is often helping) to change the character of various media institutions. However, here too, matters cannot be taken for granted, the core objective of SABC transformation must be overall and collective transformation, not just individual promotion.

The SACP is concerned at the staff turnover and morale at the SABC. The SACP believes that this is

due to aspects management practices (such as unilateral restructuring) and the insecurity brought on by commercialisation. These problematic management practices derive partly from commercialisation process and the dominant management paradigm that "managers must manage". In the process, management has been strengthened at the expense of SABC employees. The SACP recognises that there is an intimate relationship between the employment conditions of workers in a public service, and the quality of service.

9. CONCLUSION

The SACP hopes that the points made in this and many other submissions from sectors which represent the majority of South Africans will be taken into account as the DEPs are being finalised. The SACP will engage actively and vigorously with this DEPs process.

List of References

• Submission by COSATU on the SABC?s Draft Editorial Policies, June 2003
• SABC Draft Editorial Policies, May 2003
• Resolutions of the 51st National Conference of the ANC, December 2002
• COSATU Submission on the Broadcasting Amendment Bill, September 2002
• Position Paper on the Media Development and Diversity Agency, Government Communication and Information Services, January 2001
• SACP Submission to Parliament on the Media Development and Diversity Agency, March 2001
• SACP Submission to the South African Human Rights Commission hearings on Racism in the Media, March 2000
• "Establishing Friends of the Public Broadcaster", interview with Hassen Lorgat, Update Newsletter, Freedom of Expression Institute, January 1999
• SACP Press Statements on the SABC (October 2000, September 2002 and April 2003)