Why policies matter for engendering plural, profitable & sustainable media in Africa. A primer for media leaders.

By Guy Berger, G.Berger@ru.ac.za

Presented at Konrad Adenauer Stiftung Seminar on Policies & Strategies for Media Viability in Africa, Mozambique, Maputo – Holiday Inn (9-12 February 2005)

1. Summary: 

Policy plays a major role in media growth in Africa. But it is typically under-rated. Strategy is sometimes considered by media leaders, but policy is a poor cousin. The point is that most media leaders tend to take policy issues for granted, or in piecemeal fashion. But greater and more considered awareness about the role, place and power of policy, and about its complex character, can lead to more effective leadership and management across a range of fronts. To show this, this paper explores a number of important matters: the “policy sea”, internal-external-personal dimensions; a “policy sandwich”; policy philosophies; the “policy cycle”; policy “paradigms”; and finally, pointers towards a checklist of bad and good policy practice.  This comprehensive examination of the key issues of policy is intended to demystify a field that is often foreign to people who have risen to become media leaders. 

2. Introduction:

As media people, we don’t always notice that we are continuously swimming in a sea of policy – often not of our own making, occasionally choppy, sometimes murky, not always predictable. Our context is one shaped by real effects of policy (and of non policy). But the role of policy is such that we are mostly unaware of its status as the lynchpin that it is. 

These generalisations frame the situation of most of us. Thus, if you reflect on things, you may recall occasions, for example, when you made reference to the need for a particular policy. Or when you underlined the need to enforce a policy better; perhaps even revise some long-standing policy. Then you will probably have had times when you’ve expressed opinions about government policies, especially about those that impact upon media as an institution and business. 

Other than such instances, most media leaders (along with most people in society) tend to go about pressing daily, or even monthly, business. Dealing with this or that, troubleshooting here and there, crisis managing, strategising, hiring, firing, mentoring, being focused on specific stories or on business performance, fending off or befriending politicians, doing budgets, tweaking work-flows and technology options, policing standard operating procedures, etc., etc. 

Meanwhile, and usually unobtrusively, policy – or, equally, a policy vacuum – impacts on all these time-consuming and attention-absorbing actions. Policy is there in the background of what we do in order to keep afloat and make progress – it is embedded in managing, leading, organising, controlling. 

We’ve been journalists, businesspersons, not policy-makers and policy-analysts. We’ve had little formal training in understanding policy; we fly by our gut instincts when we are doing policy. Now we can move to a more intellectual level in dealing with this tricky topic. 

My argument in this paper is that we can do well to pay more attention to the undercurrents of policy, to surface these into our consciousness, and seek to improve upon them. Doing this can make us a whole lot more effective in relation to many, many of the specific and short-term issues facing us on a day-to-day and month-to-month basis. In short, your leadership can benefit from more conscious understanding of policy and its practice. And your impact, as a result, can be increased to new levels through leadership that works in a way that is optimally planned, sustainable, systematic and regularly reviewed. 

My invitation therefore is that you start thinking, dreaming, eating and sleeping about policy as a particularly valuable element of media leadership. This is policy whether formal or informal, whether living versus dead-letter. It is policy when it is lip-service symbolism, and also when it is something that has further substantive impact. And let us not forget that the absence of a given policy, or the absence of implementation, itself often constitutes nothing less than a de facto policy with very particular effects.  

3. Internal, external and personal policy:

Policies relevant to media leaders can be distinguished in several ways, the most important of which are probably those that are internal to the media house or company, and those which are external to it. 

External policies often emanate from governments, and are often put into effect with the force of law. They may impact upon the structure of the media industry, or on the content, or on both dimensions. For example, national broadcast licensing policy (or lack thereof) will determine the extent of competition; the independence and the financing of the public broadcaster; the viability of local content producers; the role of broadcasting in the cultures, languages, education and politics of a nation. Very often, too, there are policies that regulate election coverage. 

Most of these external policies tend to be negatively phrased – as to what may not be done. For example, as a media leader you may not grow your media house too big or too wide; you should not allow your media to propagate illegal content. But some external policies can also be positive – eg. in South Africa, government policy led to the launch of the Media Development and Diversity Agency, MDDA, which helps subsidise small-scale media. The point is that external policy need not be only characterised by problems, but also by possibilities. Don’t limit yourself to seeing policy as only constraining and setting boundaries – it can sometimes be highly enabling, even liberating.

Media leaders obviously have to pay attention to particular national policies for the media sector. But there are also many other governmental policies which are broader in intent and reach, and yet which still impact directly on the media environment. For example, these might be political policies that curtail freedom of expression, or which deal with the right of citizens’ access to public information. They may be education policies that impact on literacy; economic policies that lead to high tax on newsprint; competition policies that prevent forms of foreign- or cross-ownership; telecoms policies that determine costs of internet access and therefore the viability of online publishing; labour policies (backed by law) that determine parameters for internal HR practices. There may also be international policies that have a bearing – eg. on interest rates; trade and tax regimes; poverty; development aid or debt relief. These can also be highly significant for a media house. 

Internal policies can be said to be those operational within the media, even if they frequently exist within the kinds of external national policy and regulations discussed above. Internal policies may apply across a media company (eg. leave conditions; sexual harassment; HIV-Aids issues, performance review, smoking indoors, cellphone reimbursement; etc). There are also those policies that are unique to, or which impact upon, editorial most directly. The quality of editorial independence from management and advertisers is a large issue here. Consideration of internal policy should - as with external policy – keep cognisance of situations in which a lack of policy is significant. The vacuum may sometimes suit a given status quo, or sometimes compel players to simply improvise as they go along. 

Typical newsroom policies cover topics like: acceptable newsgathering methods; coverage of HIV, suicide, rape; freebies; bribes; plagiarism; payment of sources. Other newsroom policy areas might cover subjects like: internet use; advance sight requests by sources; corrections & apologies; fairness and balance; protecting source identity and testifying in court; digital manipulation of photographs. Policies may also be about the character of gender and race coverage; electoral ethics; disclosure of sources; relations with rivals; etc. There can also be, but sadly often there are not, policies around training of journalists.  

In addition, internal policies need to be viewed, as with the external policy environment, as not being exclusively in the realm of strictures and proscriptions. Instead, internal policy can propel empowerment. For instance, a policy on internet use may ban the access or distribution of pornography; yet it can also go further and suggest training programmes to ensure that online resources are used to maximum research effect. 

A last thought concerns personal policies – these may also be significant to a media leader. For example, you may practise policies that you will never reprimand a staffer in public; that you won’t micro-manage; that you will reward yourself with some family time; etc. These are probably policies of your making, however – unlike those of the government or the institution. 

In short, the effective policy environment within which you operate includes the broad national and international context, as well as the specific context that is internal to a media institution, and not forgetting your personal policies. There is often a relationship between the three. Media leaders should be aware of this policy context, and of the way in which policy can be phrased in negative and positive ways, that can be restricting or enabling. What follows is a value-add for you as a media leader: getting a close fix on the place and power of policy. 

4. The policy sandwich:

In everyday speak, the way we use the word “policy” tends to entail the following as synonyms that can help us understand its meaning. There are three levels here:

•	WHAT: Policy is often presented as being: a “framework”, or a “plan”, or a “rule”, or a “law”;
•	WHY: The function of policy is often seen as being to: “guide”, “direct”, or “govern”. 
•	WHERE FROM: Policy is often assumed to be about packages of “principles”, “norms” or “standards”. 

Clearly from these words, especially in the order in which I have presented them, “policy” can be defined along a spectrum with a weak meaning at the one side, and a strong one on the other. Thus in the weaker sense; it is a framework helps to guide according to principles; in the stronger, policy amounts to a law or set of rules that work to govern according to standards. 

Implicit in this is a distinction (despite the interrelationship) between the WHAT of “policy”, the WHY and the WHERE FROM. People often conflate these matters. My conceptualisation of the distinctions is in the form of a “Policy Sandwich”. In terms of this, policy is the cheese (or for carnivores, it is the meat of the matter). It is the WHAT, in the centre of the sandwich. The bread beneath it is the WHERE FROM, and the slice on top, the WHY. Hopefully, there is also a garnishing on top, i.e. the HOW, else it is likely the dish will never be consumed. The sandwich is delivered on a plate of strategy.

The first point to stress in this integrated metaphor is that the “policy meat” rests upon something under it, whether recognised or not: namely values and principles, possibly elaborated in the form of a vision plus a purpose/mission. Without clarifying what a given policy is based upon in this regard, it is not easy to develop it consistently. You don’t know if your sandwich builds its flavour on a base of rye or white. You need clarity on the wholewheat mix of values in regard, for instance, to the social worth of media and the money-making dimension of the business. Are you publishing in order to make money, or making money in order to publish? Which value is primary? 

Still on the theme of the sandwich layers beneath the cheese, it can be noted that many policies are also based on a layer of research – whether informal or formal. This is when there is butter on the bottom half of the policy bun, and naturally this is usually better than a dry bread offering. 

The second point to underline is that a sandwich needs a top slice of bread, i.e. WHY it is a sandwich, and completing the meal with a sense of HOW. Thus, the top slice deals with the appropriate mechanism to achieve the purpose – it serves to bring out the flavour of the filling by “guiding”, or “directing” or “governing”. Accordingly, it also determines the appropriate mechanisms for implementation (i.e. it sets out the codes, rules, protocols of the policy, etc). 

Third, it can be noted that the whole feast needs delivery – hence it should rest on a grand plate of strategy. This should include patterns that spell out the terms of the eating. In other words, how compliance will be assessed and the extent of success will be measured. It will thus include a programme of action, and a monitoring and review sub-strategy. There may well be pointers to the more intricate designs that give us the names of the responsible agencies, a communication strategy and a budget. 

Further, one can say that one’s use of the “term” policy, and whether it leans more to the values base, or the application top slice, of the sandwich, may well vary with the issue at hand. An internal policy on plagiarism, may be much in the way of a rule; an internal policy on trying for gender equity in sourcing is more in the way of a guideline. These are different kinds of meals – but still policy sandwiches. In the external policy environment, a policy on freedom of expression can be a supreme principle (and Supreme Court endorsed rule as in the US constitution along the lines of “no one may interfere with free speech); or it can be a less codified cultural tradition (as in the UK). 

Finally, and of great importance, the sandwich does require that the actual filling be defined, so we know whether it is ham, cheese or ham-and-cheese. A policy on plagiarism can only work if there is an explanation of what actually constitute this behaviour. Likewise, a policy on gender equity or sexual harassment. Or, in the external environment, it is essential for policy to define what public service broadcasting means and how this differs from commercial broadcasting. Especially when the public broadcaster competes for advertising in the same market as the private broadcasters.

My contention is that policy should be viewed as a distinctive layer in amongst a range of related ingredients of a meal. The design of the whole should tell us how nutritious or not, the meal is likely to be.  Conversely, when we’re eating (or avoiding) a policy sandwich, or dealing with a vacuum of no sandwich), we should be able to sense if there is something missing, or whether our top slice is half-baked, and if there’s a contradiction between the kind of cheese in the middle and the type of bread on either side. 

In addition, we should be able to track a lot back to the character of the filling at the centre, remembering its centrality to the meal. Does the filling do justice to its underpinnings? Is it defined sufficiently, and is it substantive enough, to inform the parameters of the top slice? And is the strategy plate insubstantial in terms of support for the tempting offering that we would like to serve up? Lastly, if we’re hungry or unhappy with various foodstuffs in our environment, to what extent can we go back to the kitchen and assess the expertise of the chefs who’ve given us a slice of burnt toast instead of a full sandwich, or cheated us by skimping on the key ingredient in the middle.

A final insight from this metaphor is that we can note that a model macro-sandwich can serve as the model for smaller-scale sandwiches. Thus, the strategy plate may well contain further sub-sandwiches – modelled on the structure of the bigger one. Thus one giant policy sandwich – with all its features - can well give rise to edible chunks in the shape of tinier sub-sandwiches, each in turn with their own full complement of values, implementation elements, strategic import, etc. 

For these reasons then, I invite you to remember “sandwich” when you think of policy. Because unless we always locate “policy” as a distinct element within the broader layers, we’ll never quite grasp its power to nourish our leadership capacity.  

This invitation to partake of policy sandwich thinking is also extended to working journalists, and not only the captains of the industry. Too often, journalists report on issues without locating them in the policy sandwich. For example, at Rhodes University – a campus paper reports on xenophobia amongst students. A good and important story. But the reporters fail to take the story to its logical conclusion – what is the University’s policy on the problem? The paper’s editors did not perceive that this was not just a story, but a policy issue – and that someone should be culpable to come up with a response such as evaluating the ineffectiveness of existing policy. 

Policy sandwiches, in fact, are good for most people – media leaders, reporters and the public.
 
5. Philosophies and policies:

A master sandwich has a well selected, nicely cut base, and one that should ideally set the parameters for the shape of the top slice. Thus the values and principles underlying a policy statement should have a bearing upon the edifice as a whole. As such, there is likely to be a philosophy that characterises the whole particular sandwich under consideration. These philosophies can vary in the extreme, depending on the policy-makers, but also depending on the issues attracting policy. For example, one can highlight: 
•	Libertarian/free market values:
		Light touch - abstentionist
•	Democratic values:
		Consultative, self-regulatory
•	Social democratic values:
		Directive
•	Statist/control values:
		Heavy touch

For example, internal policy on sexual harassment may entail a heavy tough style; less so in regard to a recommended guideline for journalists to seek out more female sources in their reporting. An example from the external policy environment could be: a paternalistic or repressive government will lean towards more interventionist and control-oriented policies (eg. keeping a monopoly on broadcasting), while a more democratic one or one which is not under political threat will be more light-touch. 

The point of considering the philosophies of policy is not to imply that one is intrinsically superior to the other. There are “horses for courses”, or a plurality of sandwiches possible, and there are often reasons why one is appropriate for certain occasions and consumption purposes, and not another. 

6. Why policy matters – in practice: 

Policy is presented here as the substance in the centre of the sandwich. This because of the way it flavours the whole. And looking from the outside, and down, at the top of the bread, it can be seen that the top half of the sandwich is often a function of the qualities (or the flaws) of the filling. In turn, the plate selected for the whole should also be linked to this visible surface of the confection.

But there is more than this, as to why a policy sandwich matters. The difference between a policy sandwich and an ad hoc nibble is profound. A policy is not just a one-off behaviour (no matter whether value based or manifested in codes or rules). Rather, a policy sandwich (as a writer called Colebatch has highlighted) entails the characteristicis of Authority, Legitimacy and Cause-Effect (interventionary) assumptions. The policy package may be formal or informal, but what differentiates it from non-policy, is that it is presumed to carry real weight, and that it is ongoing in its effects. In other words, a policy sandwich is based on a recipe that is expected to be influential over a period, and in application to a range of activities.  We are talking a meal, not a snack. 

Tackling these points in a little more detail, it is clear that policy involves responsibility and power, and that it requires a degree of acceptability in order to be effective. There is also the assumption that policy is supposed to achieve certain purposes – and here we need to be sensitive to possible disjunctures. A beef sandwich may be intended to nourish a growing child. But if the meat is too rare in the cooking, and therefore too red in the colour, the kid may decide to become a vegetarian. A badly-done cheese sandwich given to an investor with a sensitive stomach may make him sick and swear to steer clear of such concoctions in future. 

Briefly, there can be two hitches concerning the cause-effect assumptions of a policy. First, there may be unexpected effects. For example, South Africa adopted a policy to protect the national telecoms operator from competition on condition that it rolled out services for the poor. An unintended effect was that the lines, once put in, had to be cancelled, due to lack of payment at the end of the month by the new recipients. However, poor people were successfully brought into the telecoms loop through cellular services on a pre-pay system. Cellular telephony that now reaches some 16 million people was anticipated by policy-makers a decade ago to be useful only to a market of half a million business executives.

The second hitch concerns the lack of implementation, or uneven implementation, in leading to cause not producing effect.  Indeed, often policy is seen as being ineffective, as being talk without walk. But such failure of implementation may well be not just a function of inefficiency or lack of capacity. Rather, the problem may lie with the original policy. Perhaps it contained blindspots in regard to the reasons for implementation failure; maybe it was too unrealistic in its propositions. It may also be that the policy is made on the basis of poor research, and is accordingly unfit for purpose – not matter how good the implementation might be. 

To use our metaphor, the sandwich in this instance is not designed in full, and with all information at hand. In addition, instead of being served on a plate with appropriate patterns, it is dumped on a blank slate or one with illegible scratches. The point therefore is that problems in implementation are not necessarily just that: they often descend from problems in the original policy model. 

The paragraph above implies that for policy to work, it ought not to be some kind of pie-in-the-sky food – an unattainable wishlist of what would be desirable. The sandwich is for eating, not for day-dreaming about. On the other hand, there is also a valid argument that policy, where appropriate, should also encourage aspiration with regard to its impact – i.e. that it should entail “stretch” if it is to be fulfilled. In this sense, the vision/mission under-slice of the policy sandwich would be given special attention. And while the resulting policy would still then be realistic, this would not be taken as the same as being conservative. This kind of sandwich should be something to be hankered after and achievable through optimum implementation.  To give an example: a standard operating procedure is a kind of policy that is conservative in nature; a policy to train staff to use new technology to the fullest is one that has aspirational character. 

A final point to consider under this section is a more considered look at the relationship between policy and strategy. If policy is the sandwich, and the plate is the strategy, which comes first? Does strategy follow or precede policy? The answer is: both. A strategy is needed to implement a policy, but policies are often devised to give effect to a strategy. For example, it may be policy to charge cancellation fees or to systematise discounts for advertisers; this in turn can have its roots in a strategy to maximise advertising revenues – and it can lead to further strategies such as educating advertisers about the policy. 

The relationship between policy and strategy can also be assessed in terms of the different raison d’etre of each. Policy sets parameters, strategy is a plan to advance objectives within, against or around these parameters. For instance, government policy on broadcasting sets certain “rules of the game”, sometimes codified in law and enforced by a regulator. Strategy by an interested media company in a response to such policy might be to seek advantage by means of the policy, to change the policy or to find gaps or areas not covered by the policy. Internal policies may well be elaborated as part of such strategy. 

Without policy, strategy amounts to no more than short-term or once-off tactics. Without strategy, policy is a pretty empty affair. The point is that policy and strategy work hand-in-hand. Or, to put it another way, savvy media leaders can profitably operate with policy in one hand and strategy in the other. It’s a lot better than being bare-fisted.  

7. The process of policy:

In the policy sandwich perspective, the implicit idea is that the sandwich gets built from the bottom up, served on a suitable platter, and then consumed. That’s a neat picture that does not always conform to reality. Likewise, there is a similarly linear view in a lot of policy theory. Thus, a number of writers see policy as an automatic flow system, going through a logic of stages. Thus, these writers describe a “circuit” which commences with problem identification and then moves to policy initiation and research. The next stage is policy formulation, followed then by the further logical stages of implementation, monitoring and review. The cycle then repeats itself ad infinitum.

The real world is rather different. Policies are sometimes (often?) retrospectively developed. They may often not be implemented – let alone monitored or reviewed. Formulation is not limited to the formulation stage – there is often policy being changed or new policy being made in the middle of implementation. 

Nonetheless, it can be of value to treat this linear view not as a description of real stages of the policy process, but as a guide to distinctions between “moments” within the whole. This helps us recognise the limits of a snapshot view of a policy sandwich, and instead to be aware that the whole thing is in process. It highlights that there may (or may not be) different kinds of activities present therein. The sandwich may be eaten sideways or dismantled in the eating; it may stand on a shelf and get stale, or be wolfed down with nary a thought about the taste. It may be consumed with the consciousness of improving the recipe for the next concoction. So we should be sensitive to initiation, formulation, implementation, monitoring, evaluation, and review. 

Probably, too, there is a model process that is implicit in the linear flow view. After all, one ought not to start eating the policy sandwich before it is completed. Or start researching the ingredients when the item is already being chewed. There should be a clear research stage, a formal implementation stage, a monitoring stage, and an evaluation of policy practice and impact. And finally there should be a review built in. So, let us not entirely trash the textbook ideal of policy, even if it is clear that a fair amount of salt is needed so that we don’t confuse practice with theory.  

8. Policy processes, places and actors: 
 
Getting closer to policy practice, we can utilise the classic journalists’ questions to help us understand policy as a living issue on the ground. Who, what, where, when, why, how, so what?

Here the questions are, with some possible answers: 

Who is involved?
Governments, presidents, MPs, business, civil society, IMF, regulators, judges, consultants, editors, staff. Everyone can in theory be a “policy-maker” – and we need to look beyond the obvious suspects. Who is affected by policy is also important to consider. 

Where are they?
Parliament, president’s office, civil service, courts, media, Geneva, New York, Pretoria, boardrooms, golf-courses, etc. And yes, some policies may be decided in the bedrooms (I am talking here of Hastings B and his official Hostess, not of your personal policies regarding safe sex).

When are they involved?
Law-making, crises, social and technological changes, political pressures, court cases.

How are they involved?
Lobbying, research, public and/or private processes; degrees of implementation, non-compliance; even sabotage and filibustering.  

Why policy?
- to solve problems, to pre-empt problems of particular groups
 - to enable and empower

So what? The answer: to intervene 
 - to underpin law, regulation, conduct that should have certain social effects.
 - but remember the implementation gap (discussed above), and there are issues of budgets, resources, capacity. 

In summing up, we can begin to grasp the empirical realities of the policy sandwich by applying classic journalism questions. This method is relevant not only to media leaders, but also to reporters on the ground who ought to be asking the full range of questions about stories (assuming, of course, that  - unlike the xenophobia story journalists - they at least do perceive the policy angle in the given story). 

9. Getting paradigm perspectives: 

The policy sandwich looks different according to the light shining upon it. Or, to put the focus on you, the viewer, in terms of the sunglasses you’re wearing when gazing at it. There are a number of different perspectives that can be compared here, all of which highlight some features of policy – and ignore others. 

Paradigms 1: Functionalism
Policy in this outlook is regarded as a system to harmonise and align behaviours in the interests of the reproduction of the whole entity. This approach highlights common interests and consensus. It thus sees policy playing the role of integrating different forces. As such, the point of policy in this perspective is to provide for predictability, and to avoid ad hoc actions. To do this, policy must spell out the agreed rules of the game, and ensure that there are unambiguous roles that are clearly understood by the various players.

This paradigm is temptingly clear as an account of the preconditions for effective policy.  But it has some blind spots – and in particular, it ignores the politics of policy. 

Paradigms 2: Liberal pluralism 
Policy in this view reflects differing interests in competition and contest. The perspective assumes that the outcomes will depend on the amount of pluralism present, and on the possibilities for informed choices and debate amongst those making policy. And even though policy formulation may eventually entail aggregation and compromising of differing interests, even this is not necessarily stable: the politics can continue in the implementation (or non-implementation) of the policy.

Again, we have a paradigm that sensitises us to an important dimension of policy formulation and practice. But also again, we find that something else is ignored – namely power. 

Paradigms 3: Power
In this perspective, policy is about authority and responsibility. Politics and contestation around policy does not necessarily happen between equal parties, with the most rational proposals winning the day. Policy is very often about the exercise of power by those with power. But by the same token, wielding power is intrinsically bound up with responsibility, so this approach also highlights where “the buck stops” – where final authority and accountability lie for formulation, implementation and review of policy. It sensitises us also to noticing that much power in policy comes less from the policy-initiators and policy-makers than from implementers - the mandarins, mundane bureaucrats, and mid-level newsroom staffers, charged with delivery of the sandwich to society. 

This perspective is further valuable in reminding us that policy is sometimes about legitimisation – about the symbolism that something is being done. It reminds us of political parties purveying their policies during elections, and going on to change them once in power. But the focus on the top-down power dimension of policy can also hide a different dimension. 

Paradigm 4: Radical democrat
This grassroots view observes that policy is not so much a tool to be brandished unchecked by those with power, as something that is often constrained by those at the bottom of the heap. It indicates how grassroots actors can impact on policy, even by active non-co-operation, and set its parameters accordingly. It also implies that effective policy should explicitly go further than recognising the role of the liberal pluralist elite of active stakeholders, and explicitly canvass the views of grassroots groups whose experiences and insights can often enrich the policy outcome and make a difference to implementation. The radical democratic paradigm also puts value on the notion that policy can empower and liberate; that it does not only have to be about strictures.

Being conscious of bottom-up policy aspects is a valuable insight. However, there is a danger of it becoming a romantic populism that reduces the role of trained expertise in policy formulation and implementation. This insight about a policy free-for-all is provided by a fifth approach. 

Paradigm 5: Chaos theory
This outlook sensitises us to several situations. One is when there is a policy vacuum – and the fact that “no policy” can in fact be a policy, in the sense of allowing authorities to avoid having to develop something to which they can be held accountable. In this sense, chao can also serve power. Also according to this paradigm, even when there is policy, it is often ad hoc, inconsistent, arbitrary, half-baked, unknown, arcane, or ineffectual. Chaos also exists when there are too many policies, and a lack of integration and prioritisation. The chaos approach further points to irrationalities in processes, the deleterious effects of poor research, the likelihood of unintended effects, and confusions as regards roles, responsibilities and review. In general therefore, the chaos paradigm underlines what is poor in much policy – and the antidote therefore  points to some kind of functionalist order and harmony. On the other hand, chaos is not intrinsically negative. Working with this assumption, it is possible to see dangers in a situation that lacks any chaos or flexibility. In other words, there can be some value in a degree of chaos within a context where policies are detailed or rigid.  

Summing up paradigm insight:
•	policy as integrative & harmonising
•	policy as contested
•	policy as power of the dominant
•	policy as potentially empowering
•	policy as a mess or vacuum

To give some brief examples about the insights these paradigms can generate as regards external and internal media policies, the following can be noted:

Paradigm	Internal policy issues	External policy issues	
Integrative	Highlights that new reporters need formal induction into company policies which should be clear, unambiguous and in the interest of the whole institution. 	When broadcasting begins to be delivered via the WWW, and when that same WWW begins to be accessed wirelessly, the national policy regime will need to recognise that regulation on a platform basis (use of the airwaves) becomes a potentially contradictory matter. 	
Contested	In introducing any new policy, eg. reimbursement for cellphone costs of journalists, be sure to plan for the diverse politics that will meet any policy proposals.	National policy processes (eg. licensing new radio stations) will be contested by a range of elite interest groups – recognising this can lead to transparent and equitable dissemination of different proposals. 	
Power and responsibility	At the end of the day, someone must be responsible for authorising and overseeing a given policy, such as newsroom training. Else it won’t happen.	Those in power have special responsibility and accountability for policies – eg. such as on Access to Information.	
Empowering	It is prudent to seek staff input, and even audience input, when designing and reviewing internal policies – for example, on plagiarism.	Policies would enable grassroots people to be able to complain about media, and indeed to set up – for example – community radio stations.	
Chaos 	If there is a policy vacuum or mess, does this serve someone’s interests? For instance, a lack of policy on “freebies” lets an editor give trips to his pals. 	Where the media industry is encouraged to grow, but other policies produce many constraints that block this, the result is a chaotic policy situation. The main beneficiary is the status quo.	

10. A case study:

The world’s top two TV newsagencies, Reuters and APTV, have adopted a safety policy for journalists in hotspots. These are major media companies – and even here there are some problems deriving, it would seem, from poor policy understanding and practice. Insight into the strengths and weaknesses of this policy have been analysed in a Rhodes MA thesis by Sahm Venter. As a policy sandwich, this safety offering has some serious nutritional problems. 

Commendably, it is based on explicit values such as that no story is worth a life. But it lacks definition as to whose life: there is silence as to whether the policy covers freelancers and temporary “fixers” and assistants.  The “top layer” of the sandwich also has commendable protocols for making life-threatening situations less dangerous for their staff. These protocols include:

•	compulsory safety training (and retraining) in assessing risks, negotiating in tense situations, and basic first aid; 
•	access to safety equipment such as bullet-proof flak-jackets;
•	the right of employees to refuse to cover a dangerous assignment. 

But the plate on which this sandwich is proffered is sorely lacking. Thus there is silence as regards strategic roll-out. There are no inbuilt plans for communicating the policy. That seems to have been taken for granted – and, so unsurprisingly, it has not happened on any serious scale. It is also not possible to assess how successful or not the policy is, because no indicators have been worked out that would provide for a form of measurement. But even if there were, there are no set down systems and timetables for monitoring and review. The compulsory refresher training courses are very rare, mainly because the policy allocates no one the responsibility for ensuring this. These flaws arise, most likely, because of the companies’ managements’ lack of policy expertise. 

A number of other flaws arise from the paradigm limits of the companies’ managements.  They have done their policy work within the limits of a power paradigm and consequently neglected to draw in working journalists.  There are several adverse consequences of this: 

First, because the policy was drawn up without all-inclusive consultation, its legitimacy amongst journalists is reduced. Some feel it is just a sop to them, and a mechanism to show insurance companies that the companies are trying to reduce casualty claims. 

Second, the document is all the poorer for failing to tap the wisdom of the reporters’ experience on the actual frontline.  For instance, some journalists say that wearing flak-jackets makes them conspicuous targets, rather than providing them with protection. But because this insight has not been fed into the policy, the document does not address this problem. 

While some journalists have exercised their right under the policy to refuse to go, for instance, to Iraq, others say they would rather make excuses in order not to jeopardise their career prospects.  How power relations within the company can undercut a policy point (and how this can be ameliorated) is not recognised in the policy documents. 

To sum up, the safety policy is one problematic sandwich. It has unnecessarily created some confusion at to whom it applies. It has not been properly communicated or reviewed. The insights of those whom it is supposed to serve have been overlooked. A degree of chaos exists regarding implementation. There is also unhappiness and cynicism amongst some of the companies’ journalists, and most importantly – there is less impact on safety than could otherwise be the case. 

11 Bad policy design:

It should be clear from this paper that bad policy is one where there are pieces missing from the policy sandwich, or where the various layers have become soggy and blurred into each other. Bad policy also arises when a policy cycle is incomplete, and when it lacks authority, legitimacy and genuine cause-effect connections.  

Bad policy according to the paradigms discussed above can be seen as follows:
•	From a functionalist perspective, bad policy is partisan and unstable;  
•	Liberal pluralism sees it as ignoring different interests;
•	The power approach highlights the flaws of failing to acknowledge power and responsibility; 
•	Radical democracy suggests that bad policy fails to see the value of grassroots input and empowerment; 
•	Chaos sees bad policy as lacking system and coherence. 

13. Good policy in general:

The obverse of the points above suggest a checklist for effective policy practice. 
13.1 Policy design should address classic journalistic questions. For eg: 
•	Why the policy? What is it about? So what? 
•	What values and research inform it?
•	Who makes it, for whom?
•	Where is it made, where does it apply?
•	How is it made, how is it applied? 
•	When should it be reviewed, and by whom?
      
13.2 There should be a clear definition of what it covers (scope):
 eg. What exactly is a “confidential briefing” if you wanted a policy on this? What is “convergence” if a government decides on a policy framework for this phenomenon?

1.3.3 Good policy also:
•	Locates itself in relation to other policies, whether internal and external. 
•	Considers what interests & politics are involved. 
•	Take steps to ensure that it is accepted as authoritative and legitimate.
•	Defines who is responsible for all its facets and processes. 
•	Specifies who communicates it and how.

13.4 Good policy further:
•	Has a match between its objectives and its implementation protocols.
•	Is assess-able (yields indicators)
•	Is clear as to what constitutes degrees of success or failure.

13.5 Lastly, a good policy document anticipates its implementation (including possible risks and obstacles), and it sets forth a corresponding strategy for its roll-out, monitoring and review. 

14. Conclusion

Policy is a management aid. To use it well internally, you need to: 

•	identify priorities for policy development.
•	devise & implement a strategy for these.
•	roll-out a communications strategy.
•	set up systems to evaluate your policy effectiveness.

To have impact on the external policy environment, you need to diagnose the processes, possibilities and characteristics.  It helps to know the strengths and weaknesses from a well-considered policy point of view, and therefore where strategic interventions can be made. 

In short, understand the gamut of policy issues and you’ll be a super-powered media leader. Policy will help you advance the continent’s media industry in its evolution towards greater plurality, profitability and sustainability. 
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