1. Introduction and purpose

This Editorial Policy sets out the standards that govern all programme content broadcast by Nation Broadcasting across every one of its radio stations and associated online and on-demand services. It is the practical expression of our commitment to broadcasting responsibly, lawfully and in the interests of our listeners.

Nation Broadcasting holds a portfolio of Ofcom broadcast licences. Compliance with the Ofcom Broadcasting Code (the Code) is a condition of every one of those licences. A serious or repeated failure to comply can result in the imposition of statutory sanctions, including financial penalties and, ultimately, the revocation of a licence. This policy exists to protect our listeners, our presenters and staff, our advertisers, and the company's licences and reputation.

The policy translates the requirements of the Code into clear, everyday expectations for everyone who makes, presents or has editorial responsibility for our output. Where this policy and the Code differ, the Code prevails; this document is a guide to compliance, not a substitute for the Code itself.

2. Scope and application

This policy applies to all content broadcast on Nation Broadcasting's licensed radio services and to content we publish on our websites, apps, podcasts, on-demand players and official social media channels.

It applies to everyone whose work contributes to that output, including:

• employed and freelance presenters, producers and journalists;
• news, travel and sports contributors;
• guests, phone-in callers and competition entrants, whose participation staff are responsible for managing;
• programming, content and commercial staff who commission, schedule or sign off material;
• any third party producing content for broadcast on our services.

Every individual to whom this policy applies is expected to have read and understood it, and to apply it to their work. Ignorance of the Code or of this policy is not a defence to a compliance failure.

3. Regulatory framework

Our output is regulated principally under the following instruments:

The Ofcom Broadcasting Code. The core content standards code for UK television and radio, made under the Communications Act 2003 and the Broadcasting Act 1996. Its sections on protecting the under-eighteens, harm and offence, crime, religion, due impartiality and accuracy, elections, fairness, privacy and commercial communications on radio form the backbone of this policy.

Broadcast licence conditions. Each station's Ofcom licence carries a Format and specific conditions, for example requirements about the character of the service, locally-made programming and the provision of local news and information. These must be honoured alongside the Code.

Advertising codes. Radio advertising content is regulated under the UK Code of Broadcast Advertising (the BCAP Code), administered by the ASA, alongside Section 10 of the Ofcom Code, which governs the transparency and separation of commercial communications.

Other law. Output must also comply with the general law, including on defamation, contempt of court, data protection, copyright, and the reporting restrictions that apply to particular legal proceedings.

4. Editorial responsibility and compliance

Ofcom holds the broadcaster, not the individual presenter, responsible for compliance. Responsibility for meeting these standards therefore runs through a clear editorial chain.

4.1 The compliance chain and referring up

Presenters and producers are responsible in the first instance for the compliance of their own output. Where content raises, or might raise, a compliance question that they cannot confidently resolve against this policy, they must refer the matter upward — to their programme controller or content director, and where necessary to the Head of Compliance — before it is broadcast. When in doubt, refer up; broadcasting first and asking later is not acceptable for material that carries real risk.

4.2 Pre-broadcast compliance

Pre-recorded material that addresses sensitive subjects, contains strong opinion on matters of controversy, names individuals in a potentially damaging way, or touches on live legal proceedings should be reviewed before transmission. Live output cannot be pre-viewed, so presenters carry particular responsibility for managing risk in real time, including the use of appropriate handling techniques and, where available, delay systems.

4.3 Records and retention

Under our licences we are required to retain recordings of our output and to provide them to Ofcom on request. Recordings must be kept for at least the period specified in our licences (currently 42 days) and longer where a complaint or investigation is anticipated or under way. Correspondence, briefing notes and compliance decisions relating to contentious content should also be retained.

5. Protecting the under-eighteens

Radio has no fixed watershed. Instead, we must judge suitability against the times when children are particularly likely to be listening — in particular the school run and breakfast and afternoon periods around the start and end of the school day, and during school holidays. The more likely children are to be listening, the greater the care required.

• Material that is unsuitable for children — including strong or offensive language, explicit sexual content and references to suicide, self-harm, drink, drugs or dangerous behaviour — must be handled with appropriate scheduling and care, and avoided at times when children are particularly likely to be listening.
• Songs, comedy and features should be assessed for lyrical and thematic content; a radio edit is not automatically safe for all dayparts.
• Where a child (under fifteen) takes part in or is featured in a programme, their physical and emotional welfare must be protected regardless of any consent given by the child or a parent.
• Drugs, smoking, solvents and alcohol must not be featured in a way that condones, encourages or glamorises their use where children are particularly likely to be listening.

6. Harm and offence

Broadcasting can include challenging and adult material, but such material must be justified by the context. Context includes the editorial content, the time of broadcast, the service on which it appears, the likely audience and the degree of harm or offence likely to be caused.

6.1 Offensive language

• The most offensive language must not be broadcast when children are particularly likely to be listening. At other times its use must be justified by context and kept to the minimum necessary.
• Repeated or gratuitous use of offensive language, even if individually mild, can breach generally accepted standards. Presenters must be mindful of cumulative effect and of listeners' reasonable expectations of the station.
• Live callers and guests can be unpredictable; presenters should be ready to intervene, apologise and move on, and to use any available delay.

6.2 Harmful and imitable behaviour

• Content must not include material that condones or glamorises dangerous, seriously antisocial or self-destructive behaviour in a way likely to encourage imitation.
• Methods of suicide and self-harm must not be broadcast except where editorially justified and appropriately handled; presenters must avoid giving practical detail. Where such subjects are discussed, appropriate signposting to sources of support should be considered.
• Demonstrations of hypnotic techniques, exorcism, the occult and the paranormal must be handled responsibly and must not claim to resolve personal or psychological problems presented as real.

6.3 Fairness to the audience

• Broadcast competitions and voting must be conducted fairly, prizes must be described accurately, and the rules must be clear and appropriately made known. This is treated in more detail in section 14.
• Simulated news, warnings or authoritative-sounding statements (for example fake emergency announcements) must not be presented in a way that could mislead or alarm the audience.

7. Crime, disorder, hatred and abuse

• Content must not directly or indirectly encourage crime or disorder, or offer practical assistance to those who would commit it.
• Hate speech — material that spreads, incites, promotes or justifies hatred against a group or individual on grounds such as age, disability, sex, gender reassignment, race, religion or belief, or sexual orientation — must not be included except where justified by context, and even then handled with great care.
• Abusive or derogatory treatment of individuals, groups, religions or communities must not be included without editorial justification.
• We do not pay, and do not offer to pay, convicted or confessed criminals for interviews or other contributions about their crimes, except where clearly in the public interest.
• Care must be taken with descriptions of anti-social behaviour, and with anything that could assist the commission of terrorism.

8. Religion

• Religious programming must not involve any improper exploitation of the susceptibilities of the audience, and must not seek to promote religious views by improper means.
• The religious views and beliefs of those belonging to a particular religion or denomination must not be subject to abusive treatment.
• Any religious programme must clearly identify the religion or denomination featured and, where relevant, the identity of any organisation responsible for it.

9. Due impartiality and due accuracy in news

Due means adequate or appropriate to the subject and nature of the programme. It does not mean that every view must be given equal airtime, but that our coverage is even-handed and does not promote the station's or a presenter's own opinion on matters of political or industrial controversy or current public policy.

9.1 News

• News must be accurate. Facts should be checked against reliable sources before broadcast, and significant mistakes must be acknowledged and corrected promptly and with due prominence.
• News bulletins and news content must be presented with due impartiality; the presenter of a news bulletin should not express a personal opinion on matters of political or industrial controversy or current public policy.
• Sources should be attributed appropriately, and a clear distinction maintained between fact and comment or speculation.

9.2 Presenters and personal views

• Presenters and phone-in hosts may be robust and may express views, but must preserve due impartiality on matters of political or industrial controversy and current public policy — for example by ensuring alternative viewpoints are adequately represented within the programme or across a clearly linked series of programmes.
• Where a personal view is expressed, the presenter should not misrepresent opposing opinions and should give listeners holding other views a fair opportunity to be heard.
• Particular care is needed with campaigns; a station must not use its output to campaign on a matter of political controversy in breach of the impartiality rules.

10. Elections and referendums

During an election or referendum period — which begins at a defined point before polling day — additional and stricter obligations apply. The Head of Compliance will issue specific guidance ahead of each relevant poll. The core expectations are:

• Due weight must be given to the coverage of major parties and to designated referendum campaigns during the election period, and appropriate coverage given to other candidates and parties with significant views and perspectives.
• A candidate in an election, or a nominated referendum campaigner, must not act as a news presenter, interviewer or presenter of any programme during the election period.
• Where a candidate takes part in an item about their own constituency or electoral area during the election period, candidates of other parties must be offered the opportunity to take part, and a full list of candidates may need to be broadcast.
• Opinion poll results must not be published on polling day until the poll has closed, and no discussion or analysis of election issues should breach the rules on reporting during the period when polls are open.

11. Fairness

• People and organisations invited to contribute should normally be told the nature and purpose of the programme, what it is about, and what kind of contribution they are being asked to make, so that consent to take part is informed.
• Contributions must be edited fairly; editing must not distort or misrepresent what a contributor said or unfairly juxtapose material to create a false impression.
• Where a programme alleges wrongdoing or incompetence, or makes another significant allegation, those concerned should normally be given an appropriate and timely opportunity to respond before broadcast.
• Guarantees given to contributors — for example about anonymity, the areas to be covered, or how material will be used — must be honoured.
• Special care must be taken with vulnerable contributors and with people who may not fully understand the implications of taking part.

12. Privacy

Legitimate expectations of privacy vary according to the place and the activity, and the extent to which the individual is already in the public eye. Any infringement of privacy must be justified — for example by an overriding public interest such as exposing crime, protecting public health or safety, or exposing significant incompetence in public office.

• Doorstepping (recording an interview or attempting to record one without prior arrangement) should not normally be used unless a request for an interview has been refused or there is good reason to believe an investigation will be frustrated, and it is warranted.
• Surreptitious recording (hidden microphones, recording calls without consent) should only be used where it is warranted, normally where there is prima facie evidence of a story in the public interest and there are reasonable grounds to believe that open recording would not obtain the material.
• People telephoning the station should be told if their contribution is to be broadcast, and telephone calls made by the station for broadcast should normally be made clear to the other party before broadcast or use; recorded calls to members of the public require particular care.
• Special care must be taken with people caught up in emergencies, victims of crime, and the bereaved and grieving; suffering and distress must not be exploited and privacy must be respected.

13. Commercial communications on radio

13.1 Separation and transparency

• Advertising must be clearly separated from editorial content so that listeners are in no doubt about what they are hearing. Programming must not be distorted for commercial purposes.
• Products, services and trademarks must not be promoted in editorial content, and there must be no undue prominence given to a commercial product or service in programmes.
• Editorial control over programme content must be retained by the broadcaster and must not be handed to an advertiser or sponsor.

13.2 Sponsorship and commercial references

• Sponsored output (for example sponsored travel, weather or features) must be clearly signalled to the audience through appropriate sponsor credits, and the sponsor must not influence the content or scheduling of the sponsored programming in a way that impairs editorial independence.
• Where a commercial reference is included in programming as part of a commercial arrangement, that arrangement must be made transparent to the audience.
• Charity appeals and community announcements must not be used as a vehicle for undue commercial promotion of a connected business.

13.3 Advertising content

• All advertising and sponsor credits must comply with the BCAP Code and must be cleared appropriately before broadcast; particular care is required with advertising in sensitive categories.
• Premium rate services used on air (for example competition entry lines) must be operated in accordance with the relevant regulator's requirements, with clear pricing and terms given to listeners.

14. Competitions, phone-ins and audience interaction

• Competitions and votes must be conducted fairly. Entry mechanics, closing times, the cost of entry and the rules must be clearly and accurately communicated, and prizes must be awarded as described.
• No competition may be run in a way that misleads the audience — for example by inviting entries after a winner has effectively been decided, or by fabricating or pre-selecting winners or callers.
• Results, where broadcast, must be genuine, and records should be kept to demonstrate that competitions and votes were conducted properly.
• Phone-ins must be handled so that callers are treated fairly and courteously, and so that the risk of offensive, defamatory or legally sensitive contributions going to air is managed.

15. Online, on-demand and social media

The standards in this policy apply to content we publish beyond the airwaves — on our websites, apps, podcasts, on-demand players and official social media accounts — to the extent that it is under our editorial control. On-demand and podcast content also carries its own regulatory obligations.

• Staff posting on official station accounts must uphold the same standards of accuracy, fairness and impartiality that apply on air, and must not use official channels to campaign on matters of political controversy.
• User-generated material (comments, messages, listener audio and images) must be moderated with the same care as on-air contributions before it is amplified or rebroadcast.
• Personal social media use by presenters and staff should not undermine the station's compliance obligations or bring the company into disrepute; where a presenter is publicly identified with the station, particular care is expected.

16. Sources, contributors and interviewing

• Information should be verified against reliable sources before broadcast; a single unverified source is rarely sufficient for a significant or damaging claim.
• Confidential sources must be protected in accordance with our commitments and the law; guarantees of confidentiality must not be given lightly and must be honoured once given.
• Contributors should be treated with respect and, where relevant, given a clear understanding of how their contribution will be used.
• Legal risks — defamation, contempt of court and breach of reporting restrictions — must be actively considered when interviewing about live investigations, arrests or court proceedings, and referred up where there is any doubt.

17. Complaints handling

We take listener complaints seriously and handle them promptly, courteously and fairly. A clear and effective complaints process is both good practice and a regulatory expectation.

• Complaints about programme content should be logged and referred to the relevant programme controller and, for matters of potential Code significance, to the Head of Compliance.
• Listeners who remain dissatisfied are entitled to refer their complaint to Ofcom, and, where relevant, to the ASA for advertising matters; we cooperate fully with any resulting enquiry or investigation.
• Where a complaint reveals a genuine error or breach, we act quickly to correct it on air where appropriate, to prevent recurrence, and to record the lessons learned.

18. Breaches and consequences

A breach of this policy is a serious matter. For the company it can lead to Ofcom sanctions including the direction to broadcast corrections or statements of findings, financial penalties and, in the gravest cases, licence revocation. For individuals, a failure to follow this policy may be dealt with under the company's disciplinary procedures, up to and including dismissal for serious cases.

The company will always distinguish between honest editorial judgements that turn out to be mistaken and reckless or deliberate disregard of these standards. Referring a difficult decision upward in good faith will never be treated as a fault; failing to do so, and broadcasting high-risk material without proper regard for compliance, may be.

19. Training and acknowledgement

• All presenters, producers, journalists and relevant staff will receive induction on this policy and the Ofcom Code, with refresher briefings issued as the Code or guidance changes and ahead of elections and other high-risk periods.
• Everyone to whom this policy applies is asked to confirm that they have read and understood it, and to raise any questions with their programme controller or the Head of Compliance.

20. Ownership and review

This policy is owned by the Head of Compliance / Director of Content on behalf of Nation Broadcasting. It will be reviewed at least annually, and sooner where there are material changes to the Ofcom Broadcasting Code, to our licences, or to relevant law. Questions about the application of this policy should be directed to the Head of Compliance in the first instance.

 

 

Appendix A: The Ofcom Broadcasting Code at a glance

This policy is built on the structure of the Ofcom Broadcasting Code. The sections most relevant to our radio output are:

Section	Subject
Section 1	Protecting the under-eighteens
Section 2	Harm and offence
Section 3	Crime, disorder, hatred and abuse
Section 4	Religion
Section 5	Due impartiality and due accuracy
Section 6	Elections and referendums
Section 7	Fairness
Section 8	Privacy
Section 10	Commercial communications on radio

The full Code is published at ofcom.org.uk and takes precedence over this summary in all cases.