General programme guidelines

The Ofcom Broadcasting Code and the 4Compliance website

Channel 4 must ensure that its programmes comply with the Ofcom Broadcasting Code ("the Code"). Producers are contractually required to make programmes in accordance with the Code. Your production team must therefore be familiar with the Code’s provisions. The Code is available from the Ofcom website. 

Content creators are also contractually required to read and be familiar with the Channel 4 4Compliance website which summarises the Code and the main laws affecting broadcasting/publication and sets out Channel 4 internal procedures for compliance for all content.

Channel 4 wishes to ensure that the methods content ceators employ when making all content are in accordance not only with our regulatory obligations but the highest standards of practice.

Legal advice

• Notes of meetings or phone calls with a Channel 4 lawyer may attract legal privilege and may not be subject to disclosure in legal or regulatory proceedings. These notes must be set out separately in your notebook and labelled as a legal meeting.
• This also applies to documents sent to the Channel 4 lawyer if the dominant motive is receiving legal advice. Documents and emails written for the purpose of seeking or confirming legal advice, particularly when they raise issues of a sensitive or contentious nature, should be headed "Privileged: for the purposes of seeking legal advice". Labelling something as legally privileged doesn't make it privileged unless it is genuinely for the purposes of seeking legal advice.
• Content creators must not disclose Channel 4’s legal advice to third parties outside the production as this can result in the protection attaching to such advice being waived.

Viewings

• It is helpful to have available a full script of the content as it then stands (including all sync, voice over and commentary) at all viewings for the commissioning editor and the content lawyer or compliance advisor.
• It is helpful to have scripts with precisely numbered cells for ease of comment. Scripts should be dated and timed so that the current version can always be identified. On fact-heavy content it is also helpful and effective to footnote sources for fact checks where those sources are not confidential.

The production team

• It is the responsibility of the executive producer and commissioning editor to ensure that the team is suitably qualified and experienced commensurate to the nature of the content.
• Any trainees and/or interns must be adequately supervised, particularly if they are communicating with contributors or researching material.
• If anyone on the production team has a personal, commercial, financial or professional connection to someone granting access for the content (including interviewees and other contributors), this must be disclosed to your commissioning editor from the outset. Consideration can then be given to whether such a relationship might leave the content open to criticism that editorial integrity may have been compromised and whether that relationship should be disclosed to viewers.
• Please tell us if you are offered any funding or payment in kind from a third party towards the production costs before you make any commitment, including an offer of funding from a government department or charity. Such funding is rarely acceptable and may breach the Code as well as undermine our editorial independence so it is vital that you tell us. This includes a contribution from a newspaper that may also be covering the story.

Content treatments, the editorial specification, notebooks and rushes

Any content proposal which may potentially bring the producers or a contributor into conflict with the criminal law or give rise to a threat of police action against the content must be discussed from the outset with the commissioning editor and content lawyer or compliance advisor.

• Content may attract the risk of legal and/or regulatory action. In the event of such action, all documents (which includes filmed rushes) produced in the course of the production may have to be handed over to Ofcom, the court, the police or even to those who are the subject of the content. This is commonly referred to as 'disclosure'.
• It is therefore particularly important that all production documents, including but not limited to notebooks, email correspondence, rushes, treatments and the editorial specification are prepared carefully and professionally without unnecessary comment which could be misinterpreted. In the case of early treatments and the editorial specification, these should be drafted carefully and claims being investigated should be framed as allegations not as fact, to avoid any perception of bias or pre-judging the investigation.
• In the case of rushes, it is particularly important that all members of the production team are reminded that comments or activity at the beginning and end of interviews or GV's or pieces to camera, are likely to be viewed and heard by Ofcom and in the case of legal proceedings by the subject of the complaint.
• It is also good practice to keep the content material separate from material for other projects in notebooks or computer folders. It may be necessary to use clean laptops or mobiles on some content.
• When carrying out investigations or work for content which may attract police attention for disclosure at a later stage, it is sensible to mark material as "journalistic material for the purposes of the Police and Criminal Evidence Act".
• Material which has not been included in the content such as rushes and/or documentary evidence must not be passed to third parties including other journalists without the prior approval of the Commissioning Head and Controller of Legal and Compliance.
• All content material including the rushes must be retained for a minimum of 12 months from first broadcast/publication of the content on Channel 4.

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