- This guidance applies to production activity where an enhanced security risk assessment is required, including all travel, recces, production and filming in remote, austere and hostile environments in the UK and abroad. It applies to all Channel 4 commissions and developments across all our genres, channels and platforms (including, for example, 4Studio).
Please get in touch with your content lawyer/compliance advisor or the Channel 4 High-Risk Team for a copy of the High-Risk Filming Guidelines
- The below is an overview of the main considerations that commissioning editors and producers must read and be aware of when planning to film in high-risk environments.
- It is an offence to offer or make a facilitation payment to a foreign public official. This section contains notes on bribery that should be read in conjunction with 'Bribery'.
- Whether a country or area within it (including the United Kingdom) is likely to be considered high-risk, hostile or dangerous will vary according to the nature of the project, the timing of any visit and the prevailing environmental, political or military conditions. It is not possible to provide a definitive list of all countries and regions which may be high-risk in the context of content production. Please liaise with your commissioning editor, content lawyer/compliance advisor and Channel 4’s High-Risk Team. Please bear in mind that destinations visited frequently by tourists may nonetheless be considered high-risk for the purposes of content production.
Working in a high-risk environment
Whenever content creators are working overseas or in the UK in a high-risk environment, whether on a Channel 4 funded development or commission, careful consideration must always be given by the commissioning editor to the safety of the team and local fixers/crew before any member of the team departs and before any production activity begins.
Just because the filming is seemingly uncontentious, tourists still travel to the country or region in question, or filming has been completed there in the past without incident, does not mean that the project is risk-free. It is the responsibility of the commissioning editor to exercise appropriate editorial scrutiny at an early stage. It is essential that they satisfy themselves that the risks to be undertaken are editorially justified and proportionate and do not place the team (including local fixers and crews) at unnecessary risk.
If a project (either at development or commission stage) entails travel to a potentially hostile or dangerous area, the team must read the High-Risk Filming Guidelines and complete a High-Risk Filming Protocol (HFP). (Ask your content lawyer/compliance advisor or the Channel 4 High-Risk Team for a copy of the High-Risk Filming Guidelines; a pro forma is attached to the guidelines.)
Content creators with input from the commissioning editor, content lawyer/compliance advisor and Channel 4’s High-Risk Team (where appropriate), are required to complete the security protocol and have it reviewed and approved in advance of any high-risk production activity commencing (including travel, recces and research trips, and all other production activity undertaken by local contacts and hires in high-risk environments) by the commissioning editor, content lawyer/compliance advisor, and the Channel 4 High-Risk Team.
In the case of the most high-risk projects, HFP approval must be referred-up to Chief Content Officer and the Controller of Legal and Compliance who will, where appropriate, brief the Chief Executive.
In all cases, for the avoidance of doubt, the final green light to film is communicated by Channel 4’s High-Risk Team.
Please bear in mind that compliance with the High-Risk Filming Guidelines may be required across all genres of content. Completion of a High-Risk Filming Protocol is not just for current affairs, documentary and factual content.
Please note that you should provide adequate time to complete the protocol, which is designed to protect the safety of your team. Last minute approvals run the risk of being rejected if they are poorly drafted and there is no good reason for the delay in submitting them. If your protocol is rejected, your team will not be permitted to commence any high-risk production activity until it has been approved. Channel 4 expects draft High-Risk Filming Protocols to be submitted with a minimum of 10 working days’ notice prior to high-risk production activity commencing.
In the event of a kidnapping, arrest or detention of a content creator or team, the agreed emergency procedures set out in the High-Risk Filming Protocol should be followed and, if out of office hours, the current affairs duty executive and duty lawyer and other Channel 4 emergency contacts set out in the High-Risk Filming Protocol should be contacted immediately.
The Bribery Act 2010 makes it an offence to offer or make a facilitation payment to a foreign public official. This may affect the team working on the ground in some countries where some local officials will demand small fees, often with malice, for the safe passage of the team across borders or to assist with the safe movement of people and equipment across checkpoints or roadblocks. In such circumstances, payments should only be made after all reasonable steps have been taken to avoid such payments and after carefully weighing up the safety of the team, which will always take priority.
The law provides a defence of duress, but only in circumstances where such payments have to be made to protect life, limb or liberty, as in the case of journalists kidnapped or detained, or to guarantee 'safe passage'. While such payments are not common, when they do arise they are often relatively small. Nevertheless, these must be properly recorded in your production accounts.
Any demands for significant payments must as always be referred by your executive producer to the commissioning editor content lawyer/compliance advisor for prior approval.
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