1.1 That’s Media Limited (the Company) and its subsidiary companies (the Group) seek to work with others who share the Group’s passion, integrity and commitment to delivering media and entertainment services in a socially responsible manner.
1.2 The Group aims to operate a sustainable business that secures shareholder value by meeting consumer demand.
1.3 The Group strives to maintain high values, standards and processes to secure its aims.
1.4 This statement is intended as a non-exhaustive summary of the Group’s principles and priorities and all aspects of the Group’s business should be conducted in the spirit of its contents.
2.1 The Group is the largest holder of local public service television channel licences granted in the United Kingdom of Great Britain and Northern Ireland (UK) by the Office of Communications (Ofcom). The Group believes that these licences are able to provide the foundation for a television network that serves audiences in communities who may feel under-served by many other media providers.
2.2 It is intended that the Group’s commercial activities shall substantially fund the generation of local news content. The Group’s business model uses revenues from network entertainment programming to financially support its news production. The Group seeks to build a substantial television business with the size and scale to offer:
2.2.1 a space where a range of issues, views, people and organisations secure coverage, enhancing the diversity of voices and stories broadcast in UK towns and cities of many different sizes;
2.2.2 a platform for talented journalists to develop their work; and
2.2.3 an antidote to the perceived metropolitan outlook of some other television networks.
2.3 The Group believes that true public service television ‘receives’ as well as ‘transmits’. By engaging with viewers in UK towns and cities, the Group aims to make a distinct contribution to UK media.
2.4 The Group delivers its core broadcast news services free-at-the-point-of-use and independent of commercial interests.
2.5 The Group recognises the potential for conflict with today’s societal values when broadcasting classic television and film content. The Group seeks to act in good faith with regard to these works. The Group’s policy is to broadcast messages at the start of programming if it believes the content has the potential to cause offence to some viewers.
3.1 The Group seeks to work with others with relevant competence who share its values. The Group’s guiding principle is to foster working environments where everyone feels welcome and respected.
3.2 The Group is accredited by the Living Wage Foundation and ensures all of its staff are paid no less than the real Living Wage. All staff, agents and contractors (Team Members) should be aware of the terms and conditions of their employment or engagement which shall be fair and consistent with good industry practice. Work experience and apprenticeship programmes, where used, shall comply with all applicable laws and take account of advice from experts in the field.
3.3 The Group expects Team Members to act with integrity towards one another and the business and exercise a high standard of business practice and ethics. Effective communication should ensure that all those who work with the Group or on its behalf are aware of the Group’s expectations. All news producers and reporters shall be issued with guidelines setting out the values and standards which the Group upholds. The Group believes in maintaining a supportive environment and establishing two-way communications. As part of its staff recognition programme, the Group runs an award programme recognising outstanding local news delivery by Team Members.
3.4 The Group believes that everyone has a role to play in creating a safe and welcoming working environment for themselves and others. The Group has a written health and safety policy that is reviewed at least annually. Team Members are notified that health and safety takes precedence over production deadlines. Before entrusting tasks to others, the Group will take appropriate account of their capabilities with regards to health and safety.
3.5 The Group does not tolerate harassment (sexual or otherwise), or bullying in any form. The Group respects difference and will treat all Team Members fairly. The Group is committed to making reasonable adjustments to enable it to work with people with disabilities. The Group is an active champion of the creation of opportunities in journalism, including opportunities for people from less privileged families or backgrounds, and will consider means of contributing to forums with other media service providers who share this aim.
3.6 The Group is committed to supporting the wellbeing of Team Members in and out of the workplace. The Group subscribes to a third party employee assistance programme providing all staff with a confidential and independent telephone helpline 24 hours per day and access to free counselling.
4. Modern slavery
The Group will publish an annual statement in accordance with its policy of minimising the risks of modern slavery or human trafficking in its business and supply chains.
5. Personal data
5.1 The Group has adopted policies designed to ensure compliance with applicable data protection legislation.
5.2 Data received should not be used for any personal gain, nor for any purpose beyond that for which it was intended.
5.3 The Group will give consumers information on their rights concerning their data, as well as ways to contact the Group with questions or concerns.
6.1 The Group is committed to seeking the most appropriate ways to minimise any negative impact it has on the environment.
6.2 The Group aims to use natural resources efficiently and promote the principles of ‘reduce, reuse and recycle’. The Group pays particular attention to waste minimisation and resource efficiency and to ensuring it sources safe and sustainable materials where practically and economically feasible to do so. In accordance with this approach, the Group seeks to avoid printing where possible, and strives to implement ‘paperless’ productions (where running orders are distributed electronically).
6.3 The Group promotes the use of public transport rather than private motor vehicles where safe and practical to do so and the use of remote video facilities when appropriate to reduce the need for travel.
6.4 The Group uses lower power fluorescent or LED lighting fixtures where feasible, rather than power consuming incandescent studio lighting. The Group seeks to put in place sensible controls for energy usage and encourage its suppliers to offer energy-efficient equipment. When energy contracts come up for renewal the Group shall use reasonable endeavours to contract with renewable energy suppliers consistent with the principle of achieving long-term sustainability in all aspects of the business.
7.1 The Group holds as fundamental to its success the trust and confidence of the public and those with whom it deals, including clients and suppliers. Representatives of the Group are expected to act with integrity in their work conduct.
7.2 The Group has a corporate hospitality and gifts policy which provides rules and guidelines aimed at minimising the possibility of conflicts of interest.
7.3 The Group is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010. All Team Members are encouraged to report any suspicion of bribery or corruption.
8.1 The Group seeks to maximise the effectiveness of its systems in order to secure optimal performance.
8.2 The Company believes in adopting and adhering to standards of corporate governance appropriate to the size and scale of the Group. The Group will take appropriate action to protect its assets from loss, misuse, damage, theft or sabotage. The Group will periodically review its policies and procedures including its business continuity and disaster recovery plans.
8.3 Consistent with its commitment to a high degree of transparency, the Company prepares consolidated Group accounts and voluntarily submits these to independent audit review.
8.4 The Group maintains procedures intended to ensure compliance with its legal and regulatory obligations. The Group will strive to maintain appropriate dialogue with relevant governmental and regulatory bodies including by participating in relevant industry forums.
9. Suppliers, clients and stakeholders
9.1 The Group aims to build strong relationships with key clients, suppliers and other stakeholders and to understand their objectives.
9.2 The Group requires its commercial advertising inventory to be sold with integrity and, generally where practical, with reference to industry-accepted audience measurement metrics.
9.3 The Group will procure fairly and abide by applicable laws designed to prevent money laundering, criminal financing and tax evasion.
9.4 The Group will comply with all applicable antitrust, competition and trade laws and regulations.
9.5 The Group expects all suppliers and agents to work towards and uphold appropriate professional and ethical standards. The Group reserves the right to request information from suppliers regarding the production and sources of goods and services supplied. The Group may withdraw from any agreement or arrangement with a third party who is found to have acted in contravention of the fundamental spirit of the Group’s approach.
10. Public service
10.1 The Group strives to reflect the tastes and interests of its viewers, including by providing compelling entertainment and targeted local news. The Group provides mechanisms for viewer contribution and feedback, including via its website at www.thats.tv
10.2 The Group will maintain a list of helplines on its website for those who may be affected by any of the issues that often tend to be covered in its news programming such as mental health and addiction.
10.3 The Group values its independence within the political process, and does not contribute its funds, assets, facilities or services to political parties or candidates standing for public election.
10.4 The Company will review and revise its environmental, social and governance (ESG) strategy on an ongoing basis. The Company will ensure that future iterations of the Group’s ESG statement take appropriate account of changes in the organisation, legislation and stakeholder comments.
This statement constitutes a statement of values. It does not form a part of any contract between a Group company and any other entity other than to the extent expressly stated within a written agreement. In some cases, the Group also has more detailed statements, guidelines, policies and/or contractual agreements about certain subjects included in this statement. In that case, those documents may also apply and, where applicable, may be determined by the Company’s directors to take precedence.
Approved and authorised by the board of directors of That’s Media Limited, 13 February 2023