Indicators of Risks to Media Pluralism

Media Audience Concentration

Result: High Risk

This indicator aims to assess the concentration of audience and readership across media platforms based on audience share. Concentration is measured by using the nationwide biggest 4 owners in the market. 

Why? 

There is no publicly available credible audience measurement in any of the markets (print, television, radio, online) in North Macedonia. Although Nielsen is present in the North Macedonian market, the methodology and the measurements are not in usable format or were made available for the study. An association of top 5 private broadcasters, Macedonian Media Association, in the country own the Television Audience measurements (produced by Nielsen) but the data measured amounts to only about 50% of the market which indicates that in terms of audience share the top 4 might not reach the 50% threshold, however with the lack of credible data this cannot be confirmed. In principle, lack of audience data indicates risks to Media Audience Concentration because it does not allow the regulators or other actors of the market to ascertain the position and influence the media outlets might have in the market. However market shares of the top 4 players (Sitel, Kanal 5, Alsat and Alfa) indicate a market share of 81.21% which is indicative of a concentrated market.

LOW MEDIUM HIGH 
Audience concentration in Television (horizontal) 

Percentage: Missing Data 

If within one country the major 4 owners (Top4) have an audience share below 25%.  If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.  If within one country the major 4 owners (Top4) have an audience share above 50%. 
Audience concentration in Radio (horizontal) 

Percentage: Missing data

If within one country the major 4 owners (Top4) have an audience share below 25%.  If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.  If within one country the major 4 owners (Top4) have an audience share above 50%. 
Readership concentration in newspapers (horizontal) 

Percentage: Missing data

If within one country the major 4 Owners have a readership share below 25%. If within one country the major 4 owners (Top4) have a readership share between 25% and 49%.  If within one country the major 4 owners (Top4) have a readership share above 50%. 
Audience concentration in Internet (horizontal) 

Percentage: Missing data

If within one country the major 4 owners (Top4) have an audience share below 25%.  If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.  If within one country the major 4 owners (Top4) have an audience share above 50%. 

Media Market Concentration

Result: High Risk

This indicator aims to assess the horizontal ownership concentration based on market share which illustrates the economic power of companies/ groups. Concentration is measured for each media sector by adding the market shares of the major owners in the sector. 

Why? 

MOM mapped eleven TV outlets from which the public broadcaster has the biggest market share of almost half of the portion (48.7%). 

In the TV market, from the selected and mapped TV outlets, excluding the public broadcaster, the top 4 owners have 81% of the market share. Goran Ivanovski (Sitel) has 35.7% of the market share, while Emil Stojmenov (Kanal 5) has 20.9%, The Velija family (Alsat-M) has 14% and Peter Schatz (Alfa) has 10.6%. 

The two biggest owners in the radio market have more than two thirds or 87% of the market share. The top owners in the radio are Viktor Gavrilov (Kanal 77) with 47% of the market share while the three owners of Radio Antenna 5, Petrov, Janevski and Gushev with 40% total. In the MOM database four radios were analyzed. 

In the print (newspapers) market, MOM analyzed five print outlets, four dailies and a weekly. More than half of the market share (59%) belongs to the top two owners, Vladimir Galjak/Dragan Zivkovic (Sloboden Pecat) with 38% and Lirim Dulovi (Koha) who has 21% of the analyzed market share.

MOM mapped thirteen online media outlets and analyzed their market share. From the data collected and analyzed, the top 4 owners have 77% of the market share: Agnes Adamik (Kurir, Republika) with 37.5%, Aleksandar Manev (Faktor) with 22.8%, Biljana Ilic Geroska (Plusinfo) with 9.5% and Goran Mihajlovski (SDK) with a market share of 7.6%.

LOWMEDIUMHIGH
Media market concentration in television (horizontal): This indicator aims to assess the concentration of ownership within the TV media sector. 
Percentage: 81% (top 4)
If within one country the major 4 owners (Top4) have a market share below 25%.  If within one country the major 4 owners (Top4) have a market share between 25% and 49%.  If within one country the major 4 owners (Top4) have a market share above 50%. 
Media market concentration in radio (horizontal) : This indicator aims to assess the concentration of ownership within the Radio media sector.    
Percentage: 87 % (top 2)  
If within one country the major 4 owners (Top4) have an audience share below 25%.  If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.  If within one country the major 4 owners (Top4) have an audience share above 50%. 
Media market concentration in newspapers (horizontal): This indicator aims to assess the concentration of ownership within the print  sector.
Percentage:  59 % (top 2)
If within one country the major 4 owners (Top4) have a market share below 25%.  If within one country the major 4 owners (Top4) have a market share between 25% and 49%.  If within one country the major 4 owners (Top4) have a market share above 50%. 
Media market concentration in Internet Content Providers 
Percentage: 77 % (top 4)
If within one country the major 4 owners (Top4) have a market share below 25%.  If within one country the major 4 owners (Top4) have a market share between 25% and 49%.  If within one country the major 4 owners (Top4) have a market share above 50%.  

 

 

Regulatory Safeguards: Media Ownership Concentration

Result: Medium risk

This indicator assesses the existence and effective implementation of regulatory safeguards (sector-specific and/or competition law) against a high horizontal concentration ownership and/or control in the different media. 

Why?

The issues related to media concentration are regulated by the 2013 Law on Audio and Audiovisual Media Services (LAAMS), in which the following aspects are regulated in a separate chapter titled "Protection of Pluralism and Diversity of Audio and Audiovisual Media Services": the limitations regarding the horizontal and vertical integration of the capital have been determined; a ban on secret partnerships among broadcasters has been established;

The only criterion for assessing the existence of illegal media concentration within the same relevant market (horizontal integration) is the number of broadcasting licenses that one physical or legal entity can be granted at national, regional or local level, which is identified either through the capital share in the ownership of a specific company or through the shares of the related persons.   

There are several blind spots of the current provisions on media concentration: the existing rules are designed for a “traditional” media environment (radio, television, press…) and does not take into consideration the take-up of new services and platforms (non-linear services, online media, video-sharing platforms, social networks, search engines…) through which a significant and ever-growing number of people are informed, educated and entertained; the provisions are very strict in terms of limitations on geographical concentration, both in terms of licences and coverage areas; there is a ban on cross-ownership between broadcasting and newspapers which is rarely applied elsewhere in Europe and, when it is, it is only applied in large markets; the provisions about the cases of media concentration created through related persons are unclear and the specific aspects of the definition of related persons is very vague.

The illegal media concentration is determined only for broadcasters. The print media is only indirectly regulated, through the prohibition on ownership concentration between broadcasters and publishers of daily newspapers. Online media are not yet covered by the rules governing illegal media concentration.

The competent body for determining illegal media concentration is the Agency for Audio and Audiovisual Media Services, which is clearly stated in the Article 6 of the LAAMS in which the competences of the media regulator are stipulated. In addition to determining impermissible media concentration, the Agency has the authority to decide on the granting, revocation or extension of licenses for television or radio broadcasting, to take care of the protection and development of the pluralism of audio and audiovisual media services, to encourage and support the existence of diverse, independent and independent audio and audiovisual media services, to encourage freedom of expression, to take care of ensuring transparency in the work of broadcasters, to take care of the protection of citizens' interests in the field of audio and audiovisual media services, to carry out monitoring and to takes measures in cases where violations of the provisions of the law and by-laws are established, to encourage media literacy etc.

Television, Radio, print and OnlineDescriptionYesNoNAMD
4.1Does the media legislation contain specific thresholds or limits, based on objective criteria (e.g. number of licenses, audience share, circulation, distribution of share capital or voting rights, turnover/revenue) to prevent a high level of horizontal concentration of ownership and/or control in this sector?This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownership and/or control in the TELEVISION sector.1
4.2Is there an administrative authority or judicial body actively monitoring compliance with the thresholds in the audiovisual sector and/or hearing complaints? (e.g. media and/or competition authority)?This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration.1
4.3Does the law grant this body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds?

The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as:

  • Refusal of additional licences;
  • Blocking of a merger or acquisition; 
  • Obligation to allocate windows for third party programming; 
  • Obligation to give up licences/activities in other media sectors;
  • Divestiture.
1
4.4Are these sanctioning/enforcement powers effectively used?This indicator aims to assess the effective implementation of sector-specific remedies against a high horizontal concentration of ownership and/or control in the television media.1
Total         4
MEDIA MERGERSDescriptionYesNoNAMD
4.17Can a high level of horizontal concentration of ownership and/or control in the media sector be prevented via merger control/competition rules that take into account the specificities of the media sector?

This question aims to assess the existence of regulatory safeguards (sector specific and/ or competition law) against a high horizontal concentration of ownership and/or control in the media sector through merging operations. For instance, the law should prevent concentration in merging operations: 

- By containing media-specific provisions that impose stricter thresholds than in other sectors;

- The mandatory intervention of a media authority in merger and acquisition cases (for instance, the obligation for the competition authority to ask the advice of the media authority);

- The possibility to overrule the approval of a concentration by the communication authority for reasons of media pluralism (or public interest in general)); -that - even though they do not contain media-specific provisions - do not exclude the media sector from their scope of application.

1
4.18Is there an administrative authority or judicial body actively monitoring compliance with rules on mergers and/or hearing complaints? (e.g. media and/or competition authority)?This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system.1
4.19Does the law grant this body sanctioning/enforcement powers in order to impose proportionate remedies (behavioral and/or structural) in case of non-respect of the thresholds?

The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as: 

  • Blocking of a merger or acquisition; 
  • Obligation to allocate windows for third party programming; 
  • Obligation to give up licences/activities in other media sectors;
  • Divestiture.
1
4.20Are these sanctioning/enforcement powers effectively used?This indicator aims to assess the effective implementation of sector-specific remedies against a high horizontal concentration of ownership and/or control in the television media.1
Total            4

 

 

Cross-media Ownership Concentration

Result: High Risk

This indicator aims to assess the concentration of ownership across the different sectors – TV, print, audio, and any other relevant media – of the media industry. Cross-media concentration is measured by adding up the market shares of the Top 8 media companies. The results are not an indicator for economic strength in different media sectors but rather for the potential influence on public opinion when considering all media types.

Why?

In the MOM database of selected 31 media outlets, nine TV companies (the public broadcaster excluded) have 74.5% of the market share, the five print have 15%, the portion that the thirteen online media outlets have is 5.9% and the smallest portion of 4.6% of market share is from the four radios.

From the mapped media outlets, the top 8 owners across all media sectors have a market share of 80% which according to MOM methodology is high concentration. The top 8 owners are:

CBC Sitel (26.6%); CBC Kanal 5 (15.6%); CBC Alsat-M (10.5%); CBC Alfa (7.9%); CBC TV Makpetrol - Telma (7.6%); Sloboden Pecat (5.7%); Koha production (3.2%); CBC Company 21 (3.2%)

LOW (1)MEDIUM (2)HIGH (3)
3Percentage:
If within one country the major 8 owners (Top8) have a market share below 50% across the different media sectors.  If within one country the major 8 owners (Top8) have an audience share between 50% and 69% across the different media sectors. If within one country the major 8 owners (Top8) have a market share above 70% across the different media sectors.

 

 

Regulatory Safeguards: Cross-media Ownership Concentration

Result: Low risk

This indicator aims to assess the existence and effective implementation of regulatory safeguards (sector-specific and/or competition law) against a high degree of cross-ownership between media types (press, TV, radio, internet). Given the diversity of thresholds or limits that exist among different countries with regard to ownership and/or control, 'high' should be assessed according to the standards of your country and in the light of the thresholds or limits imposed by domestic laws.

Why?

Article 39 of the LAAMS refers to the diagonal concentration of capital, that is the integration of capital between the undertakings on different relevant markets. The current rules restrict the concentration between broadcasters (radio and television) and daily newspapers or news agencies. A person who is a founder of a radio or television station must not be a founder of a daily newspaper that is distributed at the same time in the area where the radio and/or television program is broadcast, nor of a news agency. In terms of concentration between television and radio, the Law is unclear.        

 

CROSS-MEDIA OWNERSHIPDescriptionYesNoNAMD
5.1Does the media legislation contain specific thresholds, based on objective criteria, such as number of licences, audience share, circulation, distribution of share capital or voting rights, turnover/revenue, to prevent a high degree of cross-ownership between the different media?This indicator aims to assess the existence of regulatory safeguards (sector-specific and/or competition law) against a high degree of cross-ownership in different media sectors.   X
5.2Is there an administrative authority or judicial body actively monitoring compliance with these thresholds and/or hearing complaints? (e.g. media authority)This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration.   X
5.3Does the law grant body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds?

The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as: 

  • Refusal of additional licences; Blocking of a merger or acquisition;
  • Obligation to allocate windows for third party programming;
  • Obligation to give up licences/activities in other media sectors;
  • Divestiture.
  X
5.4Are these sanctioning/enforcement powers effectively used?

The relevant authority never uses its sanctioning powers.

The question aims at assessing the effectiveness of the remedies provided by the regulation.

  X
5.5Can a high degree of cross-ownership between different media be prevented via merger control/competition rules that take into account the specificities of the media sector?

For instance, cross-ownership can be prevented by comptetion law: 

- by the mandatory intervention of a media authority in M&A cases (for instance, the obligation for the competition authority to ask the advice of the media authority); 

- by the possibility to overrule the approval of a concentration by the competition authority for reasons of media pluralism (or Public interest in general);

  X
5.6Is there an administrative authority or judicial body actively monitoring compliance with these rules and/or hearing complaints? (e.g. media and/or competition authority)This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation against a high degree of cross-ownership in different media sectors via merger control/competition rules.   X
5.7Does the law grant body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds?

Examples sanctioning/enforcement powers and remedies: 

- blocking of a merger or acquisition;

- obligation to allocate windows for third party programming;

- must carryobligation to give up licences/activities in other media sectors ;

- divestiture.

  X
5.8Are these sanctioning/enforcement powers effectively used?The question aims at assessing the effectiveness of the remedies of the regulation.   X
Total              7 out of 8

Regulatory Safeguard Score: 7 out of 8 (87.5%)

Ownership Transparency

Result: Medium Risk

This indicator assesses the transparency of data about the political affiliations of media owners as ownership transparency is a crucial precondition to enforce media pluralism.  

Why?

Our sample includes 11 Television stations, 5 radios, 5 print editions and 13 online outlets, in total 34 media outlets. In 91% of cases data was publicly available, i.e. traceable in public records. Only the public broadcaster Macedonian Radio Television, which is represented with three media in this database, (one radio and two TV channels), is actively transparent. Its stations represent 9% of the media in this database. 

The ownership data for 31 of the media was at least publicly available through the open databases, the annual reports of the Agency for Audio and Audio-Visual Media and the Central Registry. Unlike in most countries in the region, the business registry in North Macedonia is not open to search for free, so the data obtained through it has to be paid for. There is an exception rule for investigative journalists to obtain data with FOIA requests.

Unlike most media, the Macedonian Radio-Television, as a public broadcaster, is legally obliged to publish reports about its work. 

Ownership of the television stations, radios and the press is publicly available through the media register maintained by the Audio and Audio-Visual Media Agency. In addition, the Agency publishes an annual report on the ownership of the media, in which it is published which companies or persons are behind them.

However, the Agency has no such mandate for online media. Data about their registration, and therefore information on who owns them, can be found through the database of MARNET - the Macedonian Academic Research Network, which is open and free. That information is available solely for mk domains. Online media that have sites on other domains can not be tracked in this way. 

No company actively disguised the ownership structure or has unavailable data .

LOW (1)MEDIUM (2)HIGH (3)
TRANSPARENCY
6.1

How would you assess the transparency and accessibility of data about media ownership?

Active Transparency – 3 of 34 

Passive Transparency –  0 of 34

Data Publicly Available –  31 of 34

Data Unavailable – 0%

Active Disguise - 0%

Data on media owners as well as their political affiliations is publicly available and transparent.

(Active Transparency)

Code if that applies to > 75% of the sample

Data of media owners and their political affiliations are disclosed based on investigations of journalists and media activists or upon request.

(Passive Transparency, Publicly Available)

Code if that applies > 50% of the sample. 

Data on political affiliations of media owners are not easily accessible by the public and investigative journalists of activists are not successful in disclosing these data.

(Data Unavailable, Active Disguise)

Code if data is available for < 50% of the sample 

Regulatory Safeguards: Ownership Transparency

Result: Low risk

This indicator aims to assess the existence and effective implementation of transparency and disclosure provisions with regard to media ownership and/or control.

Why?

The Law on Media (Article 15) stipulates an obligation for broadcasters to provide publicity in their operations, namely: toward the media regulator (in such a way that by March 31 of the current year at the latest, on a special form prescribed by the regulator, they shall submit data on the operation in the previous year) and directly to the public (in a way that at least three times a year of their own program, in prime time, they shall publish data on ownership, editorial newsroom and funding sources).

With the same article, it is determined that publishers of print media are obliged to publish the ownership data in at least one daily newspaper, once a year.

The legal obligation to ensure publicity in operations applies to broadcasters (television and radio stations) and print media. Broadcasters have an obligation to provide data to the media regulator once a year, and to the public three times a year. Print media publishers publish the data to the public once a year. Online media publishers are excluded from the regulation.

Transparency ProvisionsDescriptionYes +No -NAMD
7.1Does national (media, company, tax...) law contain transparency and disclosure provisions obliging media companies to publish their ownership structures on their website or in records/documents that are accessible to the public?The aim of the question is to check regulatory safeguard for transparency towards the citizens, the users and the public in general.0.5
7.2Does national (media, company, tax...) law contain transparency and disclosure provisions obliging media companies to report (changes in) ownership structures to public authorities (such as the media authority)?The aim of the question is to check regulatory safeguard for accountability and transparency towards public authorities.1
7.3Is there an obligation by national law to disclose relevant information after every change in ownership structure?This question aims at assessing if the law provides rules on the public availability of accurate and up-to-date data on media ownership. This is a condition for an effective transparency.1
7.4Are there any sanctions in case of non-respect of disclosure obligations?This question aims at assessing if the law on media ownership transparency can be enforced through the application of sanctions.1
7.5Do the obligations ensure that the public knows which legal or natural person effectively owns or controls the media company?This question aim at assessing the effectiveness of the laws that deal with media ownership transparency and if they succeed in disclosing the real owners of the media outlets.1
Total (Mean of L-e und L-I sub-indicators)            4.5 out of 5

 

 

Political Control Over Media Outlets

Result: Medium

This indicator assesses the risk of political affiliations and control over editorial independence of newsrooms. It also assesses the level of interference by politically affiliated actors in the work of news media.

Why?

8.1 and 8.2 North Macedonia has very strict rules on prevention of media concentration in broadcasting, including the possibility for political parties, political figures, elected or appointed officials, to own broadcast media. (The rules, according to many, are now too restrictive and actively prevent further development of the market, especially in terms of its consolidation to increase the sustainability). In the past, there were media owned by leaders of minor political parties, and with the introduction of the strict rules in 2005, there was a period of prominence of proxy owners in the broadcasting sector, in the effort to avoid the different restriction or conflict of interest situation. However, combined with the rules on ownership transparency, both in radio and television, that danger has been nonexistent. Which is not to say that individual media outlets don’t clearly lean towards one or another political party. In fact, the trend has been for the major broadcasters to visibly change their editorial approaches on election day, depending on how well the opposition was doing or not in the elections. 

8.3 Print media have been an afterthought for quite some time, quickly losing relevance, at least in their physical form. There are indications that their online extensions may retain some of the influence. The owner of one of the dailies (Nova Makedonija) used to have political ambitions and has established and led a political party, but those days seem to be over. Ideological, if not party, affiliations are evident with some print media.

8.4  The situation is quite different in the online news media sector. The major political parties of the government and the opposition all have their stables of friendly news sites, and they also use their party web-sites as news-sites of a sort, to promote the party line and attack the political opponents. One illustration and indicator how widespread that practice is can be found in the distribution of state subsidized political advertising campaign funding by political parties, which all allocated all the funds available for online advertising to friendly news-sites (some of them established just several months before the elections, with that particular purpose in mind. 

8.5 Ownership is transparent and subject to strict legal rules (Law on Media and Law on Audiovisual Media Services) for broadcast and print media, the situation is much different for online media. It may be the fact that affiliation or true ownership of news-sites is a “public secret”, but political parties and the owners of outright politically or ideologically aligned news-sites seem to make great effort to cover their involvement, usually through proxy owners. Every once in a while a “scandal” emerges in public when such networks, connected to prominent political entity (party, party leader, elected public official, etc.) are uncovered and exposed in public.

8.6 Strict rules apply for broadcast media (both horizontal and vertical concentration is prohibited), and transparency rules apply to print media. The situation with online media is cause for concern, as noted above, and there is a lot of pressure to legislate for transparency of ownership and political affiliation in that area, too.

8.7 A big part of the online news-sites scene is covered by outlets established to promote the party line and attack the opponents (in government and in opposition, likewise). How much actual interference is necessary, however, is unclear, as those newsrooms were created and personnel was recruited having those objectives in mind. 

8.8 Internal self-regulatory documents, such as newsroom editorial statues or standards for individual media are non-existent in North Macedonia, with exception of the public broadcasting service MRT. Most media are members, as individual entities or through trade associations, of the Media Ethics Council, which doesn’t interfere in matters of internal relations of the media outlets and their newsrooms. Most media also formally accept the Code of Ethics of the Media Ethics Council (recently ethical guidelines were adopted specifically for the online media). 

Score: 1.88 (Medium Risk)

LOW (1)MEDIUM (2)HIGH (3)
POLITICISATION OF MEDIA OUTLETS
8.1

What is the share of TV media owned by politically affiliated entities?

The media having <30% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation.The media having <50% >30% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation.
8.2

What is the share of Radio stations owned by politically affiliated entities?

The media having <30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.The media having <50%>30% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.
8.3What is the share of Newspapers owned by politically affiliated entities? MD
The media having <30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.The media having <50%>30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.
8.4What is the share of Online News Media owned by politically affiliated entities? 
The media having <30% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation.The media having <50%>30% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician, or political grouping, or by an owner with specific political affiliation. 
8.5To what degree is politically affiliated ownership transparent? 
There is only limited politically affiliated ownership in the country and in all cases, the owners and their interests are disclosed to the public.The majority of politically controlled news media are transparent about their ownership and interests.The majority of politically controlled media are secretive about their ownership and interests.
8.6Are there laws that regulate conflicts of interests between media ownership and political parties, partisan groups, party members, office holders and relatives?
There is clear and effective regulation that highlights the incompatibility of political office (on the local, regional, national level) with media ownership and requires transparency in the case of other political offices.There is regulation, but only covers some politically affiliated groups (effectively).There is no regulation, or regulation is ineffective.
8.7Do politically partisan owners or other political interest systematically interfere with the editorial autonomy of newsrooms?
The available evidence suggests very few or no attempts at interfering with editorial autonomy.The available evidence suggests occasional interferences and/or some degree of self-censorship in newsrooms. The available evidence suggests systemic interference with editorial autonomy, which may or may not be accompanied by self-censorship in newsrooms. 
8.8To what extent is editorial independence guaranteed in editorial statutes or in self-regulatory mechanisms?
Most news media in the country guarantee editorial independence in their statutes, or they subscribe to self-regulatory codes that do so.The most prestigious news media in the country guarantee editorial independence in their statutes, or they subscribe to self-regulatory codes that do so.Neither editorial statutes, nor self-regulation mentions editorial independence, or the guidelines are not respected by newsrooms.

Political Control Over Infrastructure

Result: Low risk

This indicator assesses the political control over important infrastructural layers in the distribution, as well as in the value and supply chains of media content. It also assesses the level of discrimination in favour of politically affiliated media distribution networks. Infrastructural elements are in most cases privately owned and access is provided to news publishers for a fee.

Why?

9.1 The number of physical copies, and by extension numbers of sold copy, has fallen below any level of sustainability (the four daily newspapers, for example, now print between themselves about 15,000 copies per day). Distribution now goes through a small number of independent vendors (news-agents, tobacco shops that are still interested to carry newspapers) and a couple of supermarket chains. While in the past, there were cases of a supermarket chain (with politically affiliated ownership) refusing to distribute newspapers critical of the government, there are no indicators currently of such or similar practices. It should be noted that the one daily in Albanian language is not distributed in areas without Albanian population, although it positions itself as a national coverage paper. 

9.2 National radio broadcasters transmit their programmes using the services of the Public Enterprise “Macedonian Broadcasting” (PEMB). While there may be complaints about the annual fee radio stations pay to PEMB for the use of antennas and maintenance of the network becoming unaffordable, there are no indicators, or past instances, of PEMB taking any discriminatory action against individual or a group of broadcasters. Local radio stations usually use their own antennas to transmit programmes to their zone of coverage. 

9.3 Commercial digital terrestrial TV stations are distributed over two digital multiplexes, operated by the foreign-owned A1 Macedonia telecommunications company (owned by A1 Telecom Austria Group). The public broadcasting service has two multiplexes dedicated to its programming services. It should be noted that less than 4% of the population accesses television content through aerial antenna, and the vast majority, over 90 percent, accesses television using cable or IPTV services. There are two major cable TV networks. A1 is owned by A1 Telecom Austria, and Telekabel is owned by a Macedonian national. The leading IPTV provider, Makedonski Telekom is dominantly owned by Magyar Telecom (part of the Deutsche Telecom Group), and the government of North Macedonia owns 34.81 percent of the shares. One DVB-S service, Total TV, is owned by the Serbian United Group. The terrestrial TV broadcasters (especially those with national coverage license) have been engaged in prolonged conflict with cable and IPTV providers, centered on copyright and associated rights issues. In absence of clear “must carry” rules, they demand payments from cable operators for retransmission of their programming services, while refusing the possibility that cable operators may choose not to carry them. There were no major instances of politically motivated discriminatory actions by the distribution services. 

9.4 The major telecommunications companies (Macedonian Telekom, A1 and Telekabel) are also the leading providers of internet services, with several other smaller companies operating in the market. There have been no instances of politically or otherwise motivated discriminatory actions against any media outlet. 

9.5 While the Macedonian advertising market has many problems (available advertising spending is not nearly enough to sustain the overcrowded media scene, common misunderstandings of the very principles on which advertising industry functions, changing circumstances brought about by the digital disruption, etc.) there is no evidence, even anecdotal, of advertising agencies acting against independent media or discriminating them. Due to a pricing war that erupted between the major TV broadcasters in the late 2000s, agencies have gained the dominant position in the advertising market. The decisions on spending of advertising budgets are taken in cooperation with the advertisers, and agencies say that they listen to specific wishes of the advertisers in that regard. There is anecdotal evidence that major advertisers have been averse of spending their advertising dollars in political or news content, preferring entertainment programs and content. Another long-standing trend is for advertisers to choose to distribute their advertising budgets in a way to ensure that they will spread the spending across as many platforms or players as possible, to avoid accusations of favoring single entities for political or other reasons. 

9.6 Audience measurement in broadcasting in North Macedonia has always faced the same concerns and accusations of being non-transparent, favoring or discriminating against certain actors in the scene. The current TV ratings system was imposed by the 2013 Audiovisual Media Services Law, under which a joint industry committee was established and Nielsen was selected to perform the audience measurement. The system favors the terrestrial broadcasters (or discriminates against cable or satellite broadcasters) and currently it measures the ratings of the five national terrestrial TV networks only. They themselves are not satisfied with its reports and there are frequent complaints against Nielsen of tampering with the findings to favor individual TV broadcasters. A new system, that would cover all or the majority of the players in the market, based on the same (self-regulatory) principle of a joint industry committee is necessary. The audiovisual regulatory authority relies on public opinion polls methodology to measure audience ratings for its quarterly and annual reports for all broadcasters other than the national DVB-T networks. That methodology is also seen as not very reliable, although it provides some more general insight in audience habits and preferences. So far, it is known that the leading IPTV provider Makedonski Telekom has an internal system that is capable of presenting real time figures of what each of their subscribers is watching at any given time, but those figures are not public. There is no indication that any of those services would discriminate on political grounds. For other media platforms – print media treat the figures about sold circulation as a closely guarded secret; online media mostly rely on services like Google Analytics, and past efforts to establish a proper independent audience measurement system have failed, often for political reasons, bearing in mind the polarization of the scene along political lines. 

LOW (1)MEDIUM (2)HIGH (3)
POLITICISATION OF INFRASTRUCTURE
9.1How would you assess the conduct of the leading distribution networks for print media?
Leading distribution networks are not politically affiliated or do not take discriminatory actions.At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions.All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions.
9.2How would you assess the conduct of the leading radio distribution networks? NA
Leading distribution networks are not politically affiliated or do not take discriminatory actions.At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions.All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions.
9.3How would you assess the conduct of the leading television distribution networks? 
Leading distribution networks are not politically affiliated or do not take discriminatory actions.At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions. All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions. 
9.4How would you assess the conduct of the leading internet distribution networks?
Leading distribution networks are not politically affiliated or do not take discriminatory actions.At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions.All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions.
9.5How would you assess the conduct of the leading service providers in the advertising market?
There is no indication that major commercial advertising agencies / sales houses would discriminate against independent media.At least one of the leading commercial advertising agencies / sales houses discriminates against independent media due to political affiliations (despite having a significant audience share).Independent news media don’t have access to commercial advertising agencies / sales houses discriminating against independent media due to political affiliations (despite having a significant audience share).
9.6How would you assess the conduct of the leading audience measurement services?
Audience measurement services are in practice available to all relevant market players and comply with industry standards; transparency, non-discrimination, proportionality, objectivity and inclusiveness of the methodology and the service is guaranteed.At least one of the leading audience measurement services raises concerns related to transparency, non-discrimination, proportionality, objectivity, and/or inclusiveness. All of the leading audience measurement services raise concerns related to transparency, non-discrimination, proportionality, objectivity, and/or inclusiveness.

State Control Over Media Resources

Result: Medium Risk

This indicator assesses the influence of the state on the functioning of the media market, through control over public funds and resources, with an emphasis on the risk of discrimination in the distribution of state support and advertisement. The discrimination can be reflected in favouritism towards political parties or affiliates of political parties in the government, or in penalising the media criticising the government.

Why?

10.1 and 10.2 At the moment, state advertising is forbidden for broadcasting. There is a body of evidence that shows that local self-governments manage to direct funding towards local media (politically motivated, to promote the work of local administrations) but not in the form of classic advertising (it looks more like sponsorship, purchasing air-time, for instance, for live broadcasts from sessions of municipal councils, and other activities of the local administration). The state (government, state and public institutions, public enterprises, etc.) cannot do any media buying on television and radio, and are limited to digital and print media advertising. There is a law in the Parliament at this moment, that aims to reintroduce the ability of government and state institutions to do media buying on broadcasting media. However, the actual solutions it offers make it more of a law to establish a system of indirect subsidies for the broadcast media. While the rules may be transparent, it does not really take into account the nature and system of functioning of advertising industry, such as size or demographics of the audiences of the broadcast media, but sets a strict system of distribution of mandatory funding that needs to be earmarked in the state budget and the budgets of local self-governments, in a linear fashion. The fairness of the proposed rules is equally questionable, having in mind the fact that the proposed distribution scheme favours the national DVB-T broadcasters, which will get a huge proportion of the proposed funding scheme (65 per cent will go to the 5 biggest TV ). 

10.3 and 10.4 At the moment, the state cannot purchase advertising time on TV broadcasters. However, if the proposed changes to the Law on Audio and Audiovisual Media Services are adopted, it will amount to between 25 and 30 percent of the total television advertising market of 16 million, according to the reported advertising earnings for TV in the annual report on the broadcasting market prepared by the audiovisual regulatory body. 

10.5 There is no data available on the share of state advertising as part of the overall newspaper advertising market. On the other hand, print media (in their physical form) depend almost fully on a form of indirect state subsidies, mandatory public notices (public calls, competitions, tenders, court, notary and executioner notices) which they treat as a competitive advertising market that saw a form of price war in the years since it was legally installed. 

10.6 There is no data available on the online market either. But knowing that all political parties have their “fleets” of online news sites (propaganda mouthpieces) and the fact that unlike TV advertising, the state can engage in media buying on online media, estimates can vary, certainly above 10% for some online news media, at least. As an illustration, we can consider the conduct of political parties during election campaigns (their media buying for election campaign political advertising is fully subsidized by the state budget) when they mostly spent their allocations for online advertising to “friendly” or affiliated news-sites. Occasionally, figures are released on government’s spending for advertising on big tech platforms, primarily Facebook. 

10.7 Direct subsidies are currently available only to the print media: 50% of costs of printing and distribution, paid to the publishers upon presentation of invoices. The rules are clear and transparent and there are no indicators or complaints indicating unfair or irregular processing of the direct subsidies. 

10.8 Indirect subsidies are also available, as noted above, for print media, in the form of mandatory public notices, the legal obligation for all state institutions to publish tenders, public calls and competitions, judicial, executors or notary notices, etc. in at least one daily in Macedonian language and one daily in Albanian language. Mandatory public notices amount, according to some estimates, to over 95% of the income of the daily newspapers. Among the three dailies published in Macedonian language, they are actually treated as commercial advertising with fierce competition in pricing to attract the public notices. Print media are also subject to tax relief (privileged VAT rate). Both forms of indirect subsidies are regulated by law. 

10.9 The national news agency MIA is set-up as a shareholders company (the state is the single shareholder). It provides news and content on commercial basis, and the same rules and prices (for different packages) apply to all clients. On the overcrowded and unsustainable media market, the main issue is that many media, especially online, cannot afford MIA’s services which in the past has led to a widespread practice of “stealing” and “plagiarising” MIA’s services. As of recently, there is anecdotal evidence coming from the management that they are slowly dealing with that problem. 

10.10 Since the removal of the broadcasting fee that was charged on all TV households in 2017, and the move towards funding the public service broadcaster from the state budget (80% of 1% of the total tax revenue for the State Budget for the previous year), the funding of the public broadcasting service MRT has been neither adequate nor independent. (In fact, MRT has suffered from being underappreciated and underfunded for the best part of the 30+ years since the independence in the country). For the past 5 years, it has never received more than 0.57% of the funding it was supposed to receive, due to decisions of the Ministry of Information Society and Administration (which decides on the allocation of MRT’s budget).

10.11 The rules on appointment of steering and management bodies of the public service broadcaster MRT (the Programming Council and the Director General, respectively) were changed in 2018. The Programming Council is appointed by the Parliament, and the vote threshold was raised from absolute (50% of all MPs plus 1) to qualified two-thirds majority. While the idea was to secure greater consensus over the names that would be appointed, assuming that it would open the door for more independent people, unaffiliated with political parties, the effect was that political parties in the parliament now have a chip they can bargain with in the political horse-trading. Combined with the fact that a two-thirds majority is very difficult to secure under the proportional electoral system, the resulting situation is that the old composition of the Programming Council (but also of the Council of AVMU, the audiovisual regulator) have been performing their duties as acting members (their mandates expired in late 2021), and will remain in that position until the new Programming Council is appointed by the parliament. Without legal changes to install a solution that, while less high-minded, will be far more practical in the highly polarized political scene in the country, new appointments are not likely, at least until after the parliamentary elections in the spring of 2024. So far, political parties in the parliament, especially the opposition, have insisted on securing representation of loyal party members in the two bodies. 

LOW (1)MEDIUM (2)HIGH (3)
10.1Is state advertising distributed to media proportionately to their audience share? 
State advertising is distributed to the media relatively proportionately to the audience shares of media.State advertising is distributed disproportionately (in terms of audience share) to the media. State advertising is distributed exclusively to few media outlets, which do not cover all major media outlets in the country.
10.2How would you assess the rules of distribution of state advertising?
State advertising is distributed to media outlets based on fair and transparent rules.State advertising is distributed to media outlets based on a set of rules but it is unclear whether they are fair and transparent.There are no rules regarding distribution of state advertising to media outlets or these are not transparent and/or fair.
IMPORTANCE OF STATE ADVERTISING
10.3

What is the share of state advertising as part of the overall Radio advertising market?

VALUE:

Share of state advertising is <5% of the overall marketShare of state advertising is 5%-10% of the overall marketShare of state advertising is > 10% of the overall market
10.4

What is the share of state advertising as part of the overall Radio advertising market?

VALUE:

Share of state advertising is <5% of the overall market.Share of state advertising is 5%-10% of the overall market.Share of state advertising is > 10% of the overall market.
10.5

What is the share of state advertising as part of the overall Newspaper advertising market? MD

VALUE: 

Share of state advertising is <5% of the overall market.Share of state advertising is 5%-10% of the overall market.Share of state advertising is > 10% of the overall market.
10.6

What is the share of state advertising as part of the overall Online news media advertising market (without amounts spent on news intermediaries)? MD

VALUE:

Share of state advertising is <5% of the overall market.Share of state advertising is 5%-10% of the overall market.Share of state advertising is > 10% of the overall market.
10.7Is direct financial support distributed fairly, transparently and based on clear rules? 
There are clear rules on the allocation of direct state subsidies and, in practice, subsidies are transparently and fairly allocated (criteria may not only be based on market share, but also public interest content, underserved communities, the need for innovation, etc.)The rules on the allocation of direct state subsidies are either not clear or the process of allocation lacks sufficient transparency or shows signs of political bias.There are no rules on the allocation of direct state subsidies and/or the allocation of subsidies is opaque and/or clearly discriminatory.
10.8Is indirect financial support distributed fairly, transparently and based on clear rules?
There are clear rules on the allocation of indirect state subsidies and, in practice, access to indirect subsidies is transparent and fair.The rules on the allocation of indirect state subsidies are either not clear or the process of allocation lacks sufficient transparency or shows signs of political bias.There are no rules on the allocation of indirect state subsidies and/or the allocation of indirect subsidies is opaque and/or clearly discriminatory.
10.9Do all media outlets have access to the state-financed news agency, and do they receive quality content relevant for their news production?
There is a state-financed news agency in the country that is accessible to all news media under the same (and fair) conditions, providing objective, well-sourced information.There are some concerns related to access to the state financed news agency or possible bias in the content provided.Access to the state-owned news agency causes unnecessary burden for some news media and/or its content is biased.
10.10Do you consider the financing of the PSM independent and adequate?
The financing of the PSM is adequate, without distorting competition with private media; and the process includes sufficient guarantees against political dependencies (e.g. through licence fees)?The financing of the PSM is insufficient or could distort competition with private media; and the funding process may enable political dependencies?The financing is insufficient to a degree that quality journalism is not or hardly possible and/or the funding process is clearly under political control.
10.11How do you assess the independence of the appointment and dismissal process of the PSM management?
There are clear rules on the appointment and dismissal of the PSM management, independence from political actors is guaranteed; and in practice appointments and dismissal decisions are made based on professional considerations.Appointment and dismissal rules of PSM management may allow for some political influence and/or the practice of appointments and dismissals shows signs of bias.Rules on appointment and dismissal of PSM management clearly enable political influence and/or appointments and/or dismissals are clearly politically motivated.

 

 

 

Regulatory Safeguards: Net Neutrality

Risk: Medium risk

Network neutrality is the principle that all data on networks should be treated equally by not discriminating or charging differently in terms of users, content, sites or applications. Protecting net neutrality is essential to safeguarding media diversity because it guarantees equal ability to access and disseminate information, opinions, perspectives, etc. online, which is essential to media diversity. This indicator aims to capture the landscape of legal regulation of net neutrality as well as the specific regulatory mechanisms that address net neutrality.

Why?


The relevant EU regulation on net neutrality has not yet been transposed into the Law on Electronic Communications of North Macedonia. However, net neutrality is to a certain extent indirectly regulated in a Rulebook adopted by the Agency for Electronic Communications (AEK) in 2015, based on Article 108 of the Law which is related to the obligations of the operators of public communication networks for transparency and publication of information.

The Rulebook adopted by the Agency, in Article 2 (Definitions), defines net neutrality аs “…a principle according to which Internet traffic is treated equally, without discrimination, restrictions or obstacles regardless of (1) the entity that sends and receives data, (2) the type and content of the data, (3) the type of service and application that it's being used.”

Next, Article 4 of the Rulebook stipulates the basic principles of net neutrality: (1) Operators providing Internet access service should take measures to ensure the principle of network neutrality. (2) The operators providing internet access service should not use measures for managing the internet traffic that can block, reduce the flow rate, modify, degrade or discriminate against any content, application or service, except for load protection or network connection overload or due to mitigation of the consequences of the load or network connection overload. These measures for managing the Internet traffic should be an exception and should be transparent, non-discriminatory and proportionate to the purpose for which they exist. (3) The operator is obliged to provide its subscribers, upon their request, with information about the possible way to check and monitor the actual and minimum speed, as well as on the conditions for restricting the access to and/or use of services and applications.

Score: 4 out of 8 (50%) = Medium risk 

NET NEUTRALITYDescriptionYesNoNAMD
Does national law address net neutrality directly or indirectly?neutrality is regulated by domestic law in any way; it also aims to reflect any agreement between countries, as in the EU and countries that are part of the Council of Europe.1
Does national law contain norms that prohibit blocking of websites or content online?This question determines the degree to which a country’s net neutrality norms prevent blocking, one of the key components of a robust net neutrality framework1
Does national law contain norms that prohibit throttling of services or content provided online?This question determines the degree to which a country’s net neutrality norms prevent throttling, one of the key components of a robust net neutrality framework0
Does national law contain norms that prohibit zero-rating and/or paid prioritization?This question determines the degree to which a country’s net neutrality norms prevent zero-rating (of which paid prioritization is a common form), one of the key components of a robust net neutrality framework0
Where net neutrality is protected by law, does the legal framework recognize any exceptions, e.g. for reasonable network management?This question establishes when reasonable limits are placed on net neutrality protections versus other limits that may undermine its effectiveness.1
Norms that prohibit or limit zero-rating are successfully implemented: Paid prioritization does not take place.This question aims to flesh out the extent to which paid prioritization occurs in practice despite its prohibition in law; a number of countries with ostensibly strong zero-rating protections experience this phenomenon. This indicator may shed light on the degree of difference between law and practices on the ground0
Norms that prohibit or limit zero-rating are successfully implemented: No other forms of zero-rating take place.Same as above0
Norms are successfully implemented: Blocking and/or throttling do not take place.This question seeks to determine how the legal framework in place to protect net neutrality operates in practice with respect to blocking and throttling 0.5
Are there regulatory or other entities charged with monitoring and enforcing net neutrality protections?This question highlights whether there are authorities charged with enforcing net neutrality protections 1
Have sanctions been imposed for violations of net neutrality protections where these exist?This question may illustrate the extent to which violations of net neutrality norms are taken seriously as a matter of rule of law and political will0
Are the enforcement mechanisms in place to identify and respond to net neutrality violations viewed as effective?This question shows the extent to which net neutrality norms actually achieve their goals 0
Total (Mean of L-e und L-I sub-indicators)                   4

 

 

 

Gender Imbalance in the Media Industry

Result: High Risk

This indicator assesses the representation of women in news media, focusing on relevant newsroom policies and the share of women in management positions.

Why?

Of the 34 media outlets that are part of the "Media Ownership Monitoring" database, nine are run by women-owned companies or companies where women are the majority shareholders. According to the data, a quarter of the media are run by women, with online media taking the lead, where women own six out of the thirteen media included in this base.

The situation is a little better when it comes to women in the position of editor-in-chief. Out of 34 media outlets, 13 media outlets, or 38%, have female editors. When it comes to editorial positions, more than half are women only at radio stations, where, conversely, no women own or have founded such a medium.

With that, this base gave yet another confirmation that women are not sufficiently represented in leadership positions in the country's media. According to the 2020 analysis of the Agency for Audio and Audio Visual Media, which examined media management, the number of women in decision-making positions (in management/director and editorial positions) is lower in all television and radio stations. At the same time, it is pointed out in the analysis that journalism in television and radio stations is a field in which women are "traditionally" more numerous. 

There is no specific data regarding the gender discrepancy in salaries among the media. However, the general data from the State Statistics Office show that men earn higher salaries than women in this country.

Regarding the challenges faced by women journalists, last year's research by the organisation PINA provides a good example. Based on surveys conducted with 103 female journalists, the research showed that a quarter of them received threats of physical violence, 19.5% received threats to their lives, while over 81% of female journalists faced harassment on the Internet because of their work.

Result: High Risk

 

LOW (1)MEDIUM (2)HIGH (3)
12.1

Do the leading news media in your country have a policy aiming at a balanced representation of women in the newsroom?

Missing data

Most leading news media have a gender equality policy or other kinds of self-regulatory measures to make sure that there is adequate representation of women in the newsrooms and in management positions. Moreover, there are mechanisms at place to make sure women in the newsroom don’t encounter harassment or discrimination.Some news media have a gender equality policy or other kinds of self-regulatory measures to make sure that there is adequate representation of women in the newsrooms and in management positions. In these news media, there are mechanisms at place to make sure women in the newsroom don’t encounter harassment or discrimination.There is no gender equality policy in the newsrooms assessed, or they are not effective, leading to discrimination and harassment of female journalists.
12.2Are women journalists subject to harassment or online/ offline violence in your country?
The working environment of women journalists is safe, harassment online or offline is not common, sufficient safeguards are in place.Both men and women are harassed to a similar extent, (physical) violence against female journalists is not common.Cases of violence are reported and harassment of women journalists is common in the country, with many known and reported cases. Women are considered to be more targeted by harassment and violence than men.
12.3

What is the share of women among owners of leading news media?

VALUE TV: 2 from 11

VALUE Radio:0 from 5

VALUE Print:1 from 5

VALUE Online:6 from 13

Average of VALUES:26%

40 percent or moreBetween 39 and 30 percentLess than 30 percent
12.4

What is the share of women among founders of news media?

VALUE TV:1 from 11

VALUE Radio:0 from 5 

VALUE Print:0 from 5

VALUE Online:3 from 13


Average of VALUES:12%

40 percent or moreBetween 39 and 30 percentLess than 30 percent
12.5

What is the share of women amongst top managers of news media (such as director/CEO)?


VALUE TV: 4 from 11

VALUE Radio: 1  from 5

VALUE Print: 1.5 from 5 

VALUE Online: 5 from 13


Average of VALUES:33.8%

40 percent or moreBetween 39 and 30 percentLess than 30 percent
12.6

What is the share of women editors-in-chief (or equivalent leading editorial positions in the newsroom)? 

VALUE TV:4 from 11

VALUE Radio:3 from 5

VALUE Print:1 from 5

VALUE Online:5 from 13


Average of VALUES:38%

40 percent or moreBetween 39 and 30 percentLess than 30 percent
12.7

What is the share of women in key (board) positions in the newsroom (meaning non-editorial management positions, such as chief financial officer, head of sales and marketing, etc.)? 

VALUE TV: Missing data

VALUE Radio: Missing data

VALUE Print: Missing data

VALUE Online: Missing data


Average of VALUES:

40 percent or moreBetween 39 and 30 percentLess than 30 percent

 

 

 

  • Project by
    BIRN LOGO
  •  
    Global Media Registry
  •  
    Funded by European Union