Editorial and Compliance Protocol

1. Purpose of this document

The purpose of this editorial compliance protocol is to ensure a consistent approach across all platforms that broadcast our content, so that StrimeoTV employees and associates assume full editorial responsibility for the content they outsource or produce.

It is the responsibility of all employees working at StrimeoTV to become familiar with the content of this document and to declare that they know the rules and procedures contained therein. The report should also be issued for inspection to all collaborators and external content providers.

The protocol covers all content published by StrimeoTV on non-linear digital platforms. Including: • All video content, including informational materials and their abbreviations; full length programs; clips and spots
• Texts, images, graphics, quizzes, surveys

• Applications and other interactive elements
• competitions
• Advertisements, advertising-funded campaigns, sponsored content • Content posted by website users.

2. Law

The law applies to online content in the same way as in the case of traditional platforms, such as television, radio, printed press.
It includes, for example, provisions on defamation, intolerance and racism, protection of minors, copyright and related rights, protection of privacy as well as criminal law and anti-terrorism legislation. In addition to the legal issues referred to above, the Act of May 10, 2018 on the protection of personal data, which sets strict rules together with civil and criminal penalties for their violations, regarding the collection, storage, use, processing, providing access and to protect personal data. Personal data is any data by which a person can be identified – for example, names, addresses, phone numbers, email addresses, dates, birth, bank and payroll details, close relatives, passport details, driving license numbers or other of that kind of information.

In case of any doubts as to the legality of the material produced by them, each employee and co- worker is obliged to report their doubts to the editor-in-chief or publisher in order to possibly request consultations with the appropriate law firm before its publication.

3. Regulations

On-demand television services, e.g. VOD and some other online content are subject to
the Broadcasting Act and are subject to inspection at the request of the National Broadcasting Council.
The National Broadcasting Council has statutory powers of control, including a full scope of sanctions to enforce compliance with the provisions on media services provided on demand, including:
• Incitement to hatred
• Protection of minors
• Sponsorship
• Product placement
Online advertising accompanying on-demand services is governed by relevant laws regarding the rules for publishing advertising advertisements in the press contained in the Act of January 26, 1984, called the Press Law;

regarding the principles of publishing advertisements on radio and television contained in the Act of December 29, 1992 Radio and television broadcasting together with additional ordinances of the National Broadcasting Council of May 20, 1993, August 31, 1993, November 21, 1994 and July 6, 2000,

4. StrimeoTV editorial procedures

StrimeoTV editorial procedures include: • Editorial responsibility
• Consumer protection
• Guidelines for content types

• Other protocols
• Training
All employees in any way involved in StrimeoTV projects must ensure that they read and follow these procedures at all times.

5 Editorial responsibility

Persons ordering, creating and / or publishing content on StrimeoTV, and for external entities that are involved by StrimeoTV, are responsible for their editorial decisions. First and foremost, this includes ensuring that all content for which they are responsible
were subject to an appropriate level of editing and compliance checking at every stage

before, during and after publication.
Editorial rights are a key principle in the creative team at StrimeoTV, which means that every reporter has the ultimate impact on the shape of the published content and is responsible for how the content is perceived by the recipients.
However, reporters / producers / publishers must cooperate
during the content editing process to identify potential threats. Reporters after publishing their material are responsible for further contacts with viewers, other media and the marketing department. They are also obliged to monitor user comments and discussions on the Internet regarding the materials they publish.

The following rules specify editorial responsibility for content published on all StrimeoTV platforms:
• Persons ordering, producing and publishing content on online platforms are
Responsible for making their own editorial assessments, as well as in case of doubt should consult the publisher.

• The editorial responsibility for the content published on the site lies with the person who created the content
• The basic rule is that the editors decide and the lawyers advise.
Timeliness is a key principle – however, the content must always be checked before publication, when a problem occurs it must be immediately reported to the publisher,

In practice, all persons responsible for publishing, production and / or content publishing on StrimeoTV channels must:

• Be fully familiar with all materials produced for publication on StrimeoTV channels, regardless of whether they are produced internally or by external suppliers
• Ensure that all potentially contentious or controversial content (or material related to controversial topics) is read / checked before being published.

• Ensure that all material rights of third parties in the material are secured
• Seek legal advice before and after publication in a timely manner on any matter that may cause legal problems or require advice from a law firm (in the case of, for example, defamation, breach of privacy)
• Immediately respond to any incoming content removal requests
• Ensure before publishing that all ads (pre-movie, banner, sponsorship, sponsored content) comply with the law and generally accepted standards, in particular regarding content intended for minors
• Ensure that all external content providers are bound by a relevant agreement.

Photosensitive epilepsy (PSE) is a serious condition that can be caused

Through flashing images or some patterns. The StrimeoTV production department responsible for ordering video content must be sensitive to this risk and must ensure that all providers understand the risk and take appropriate action to minimize any negative effects. Any content that contains flashing images and / or patterns that it might cause

The supplier should report the undesirable effects associated with PSE to the person responsible for production. This will allow StrimeoTV to check the content and provide appropriate precautions to keep the risk level low for users who have photosensitive epilepsy by editing the material or posting the appropriate warning.

6 Editorial supervision process

The editorial procedure of editorial supervision is aimed at making difficult or precise decisions by those responsible:
All contentious editorial issues are properly dealt with by the most experienced people.
The order in which the case should be reported should run according to strict order:

1 publisher, 2 editor-in-chief, 3 program director, 4 general director.
There are two areas for publishing digital content or StrimeoTV activities:
1. Content and projects on StrimeoTV platforms or on third-party websites
2. Activity in social networks. When posting on social networks such as YouTube, Facebook, Instagram, you must follow the community rules provided by each of these platforms.
Note: Technical problems should always be reported to those responsible for IT

7 Online consumer protection

StrimeoTV offers security on its platforms to allow parents / adults to restrict access to content inappropriate for minors (known as Content Access Control).
• Warning information is notified of potentially inappropriate content before a user displays a specific piece of content

• Information during live broadcast to help users determine if the broadcast content may contain fragments potentially unsuitable for minors

The following are specific technologies and approaches that have been implemented to allow effective control of access to content offered to our users.
• Age ratings of programs
All content is classified by age before it is published (this data is stored in the CMS system, ready for use on StrimeoTV’s own websites as well as on external sites).

Age ratings are:
• No rating – safe at all times for all users
• 16 – suitable for persons over 16 years of age
• 18 – content intended for adults only. They don’t appear in the content we produce.

Editors must always evaluate to determine the relevance of content for the age of the audience. • Warnings (in-stream graphics, text placed on the site so that users can see the warning as content progresses)

• Transmission information (eg Time TX after the catchment area helps inform people about it expect programs with more adult content)
• Guidelines
Support information is used in all content on Channel 4’s own websites, including video, images and text.

8 Other protocols

• Guidelines for social media on Facebook and Twitter – contain instructions on how to set up and manage profiles on these social networks. They also contain tips on social media activity.