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Indicators of Risks to Media Pluralism

Explanation

Media Audience Concentration

This indicator is based on audience-related data and media consumption. It assesses the horizontal concentration of audience and readership across media platforms. Concentration is measured by using the Top 4 largest audience share for each media type. In Turkey this indicator was calculated based on respected audience share numbers received from TV Audience Measurement - Joint Industry Committee (TIAK), Press Advertising Association (BIK), National Radio Broadcasters Association (URYAD) and Radio Listening Services Organization Promotion and Publishing Inc (RIAK), and Gemius Turkey.

The circulation number of September 2018 were used for print audience data. TIAK’s October 2018 and URYAD’s (RIAK) October 2018 research results were used for TV and radio audience share data respectively. GEMIUS Turkey’s October 2018 research results were used for online audience share data.

Television:

The TV market has a medium concentration level, as the major 4 companies (Kalyon, Demirören, State owned TRT and Doğuş) represent an audience share of 44%.  It is the pro-government Kalyon Group that owns the largest audience shares in this market (15%).The Demirören Media holds 9% of the shares in the market. TRT channels which are state-controlled and responsible with public broadcasting, own 11% of the shares in TV. Doğuş Group holds 8% of the TV audience in Turkey.

biggest owner (company or group) in this sector sum of audience share of media outlets by company
TURKUVAZ 16% ATV: 12.5%
A HABER: 1.89%
A SPOR: 1.08%
DEMİRÖREN 9% KANAL D: 5.79%
CNN TURK: 1.02%
TV2: 1.5%
STATE 11% TRT KURDI: 0.05%
TRT MUZIK: 0.27%
TRT BELGESEL: 0.61%
TRT SPOR: 0.96%
TRT HABER: 1.99%
TRT COCUK: 3.23%
TRT 1: 4.34%
DOĞUŞ 8% STAR TV: 7.11%
NTV: 2.29%
TOTAL 44%

2.1 Audience concentration in television (horizontal): MEDIUM (%44)

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

Radio:

The 4 major companies in the radio market together hold an audience of 40%, which means a medium concentration.A large part (21%) of the radio audience in Turkey is owned by Doğuş Media Group. State holds 11% of the audience. Hayat Görsel Yayıncılık and Show Radio stations hold 4% of the audience.

biggest owner (company or group) in this sectorsum of audience share of media outlets by company (weighted)
DOĞUŞ21%KRAL FM: 15.88%
KRAL POP: 3.47%
NTV RADYO: 1.52%
KENT FM: 0.1%
STATE11%TRT: 9.27%
RADYO 1: 2.31%
Hayat Görsel Yayıncılık7%Radyo 7: 4.20%
SHOW RADYO YAYINCILIĞI4%

Show Radyo: 3%
Radyo Viva: 1%

TOTAL40%

2.2 Audience concentration in radio (horizontal): MEDIUM (%40)

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

Print:

Online media outlets largely coincide with major print outlets in Turkey. 5 out of 10 online news portals with a high audience, are web sites of print or TV outlets. The online news portals of Demirören Group are being excluded from the top 10 online media portals that the MoM team has researched as the Demirören Group does not publicize the audience shares of its online news portals. The rest four major owners hold 83% of the audience share so online media has a high concentration level.These are Turkuvaz Media (29%), Ciner Media (22%), Hayat Görsel (17%) and Estetik (15%).

biggest owner (company or group) in this sectorsum of audience share of media outlets by company (weighted)
DEMİRÖREN23%HÜRRİYET:10%
POSTA:7.5%
MİLLİYET: 4.6%
TURKUVAZ15%SABAH: 10.6%
TAKVİM: 3.9%
TÜRK MEDYA12%GÜNEŞ: 3.7%
AKŞAM: 3.7%
STAR: 3.7%
ESTETİK10%SÖZCÜ: 9.6%
TOTAL60%

2.3 Audience concentration in print media (horizontal): HIGH (%60)

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

Online:

Online media outlets largely coincide with major print outlets in Turkey. 5 out of 10 online news portals with a high audience, are web sites of print or TV outlets. The online news portals of Demirören Group are being excluded from the top 10 online media portals that the MoM team has researched as the Demirören Group does not publicize the audience shares of its online news portals. The rest four major owners hold 83% of the audience share so online media has a high concentration level.These are Turkuvaz Media (29%), Ciner Media (22%), Hayat Görsel (17%) and Estetik (15%).

biggest owner (company or group) in this sectorsum of audience share of media outlets by company (weightened)
TURKUVAZ29%sabah.com.tr: 23.44%
ahaber.com.tr:3.17%
takvim.com.tr: 8%
CINER22%haberturk.com.tr: 18.51%
bloomberght.com.tr: 2.67%
HAYAT GÖRSEL YAYINCILIK17%haber7.com.tr:16.51%
ESTETİK15%sozcu.com.tr: 15.47%
TOTAL83%

2.4 Audience concentration in online media (horizontal): HIGH (%83)

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

 

SÖZCÜ tirajı tescillenen tek gazete (8.10.2016) Sozcu. Retrieved in October 2016
Sözcü: Sabah gazetesi 80-90 binlik tirajını şişirerek 300 bin gösteriyor! (30.04.2016) T24. Retrieved in October 2016
CHP'den gazete tirajları için kanun teklifi (4.07.2016) GG. Retrieved in October 2016

Media Market Concentration

This indicator assesses the horizontal concentration within the media sector. Concentration is measured by using the top 4 owners. Top 4 are obtained by summing the market shares of the major 4 owners within the market.

Since financial information on market share was not available in Turkey this indicator could not be assessed. Only two media outlets have responded to MOM inquiry regarding their financial information. In accordance with the MOM methodology if the country presents data on audience, but not on revenues/market share: the market share data is excluded from the analysis, i.e., the findings are based on the audience data alone and the revenue data are considered optional.

Score: Unknown

LOW (1) MEDIUM (2) HIGH (3)
1.1 Media market concentration in television (horizontal): This indicator aims to assess the concentration of ownership within the TV media sector.
Percentage: MD
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%.
1.2 Media market concentration in radio (horizontal) : This indicator aims to assess the concentration of ownership within the Radio media sector.
Percentage: MD
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%.
1.3 Media market concentration in newspapers (horizontal) : This indicator aims to assess the concentration of ownership within the print sector.
Percentage: MD
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%.
1.4 Media market concentration in Internet Content Providers :
Percentage: MD
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

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

Results: Media concentration is regulated under Law on Establishment of Radio and Television Enterprises and their Media Services, for audio-visual media, and Competition Authority is entitled to take action against distortion of competition according to Law on the Protection of Competition.

The media legislation contains specific limits. The same company can only provide one radio, one television and one on demand broadcast service, and a real person or a legal entity can directly or indirectly hold shares in a maximum of four media service providers. However, in the event a real person or legal entity holds shares in more than one media service provider, the annual total commercial communication income of media service providers in which a real person or a legal entity is a direct or indirect shareholder cannot exceed thirty per cent of the total commercial communication income of the media sector.

There is no specific regulation on digital media, and Press Law regulates printed press; therefore these mediums' concentration is subject to Competition Authority. The law grants both authorities sanctioning and enforcement powers in case of a breach.

Competition Authority shares its decisions as well as the knowledge and experience accumulated with the public regularly. However, Supreme Council's decisions on concentration of media service providers are not public; therefore monitoring whether media service providers notified Supreme Council for a share transfer or not is not possible to determine.

Television Description Yes No NA MD
4.1 Does 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 ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is 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. X
4.3 Does 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;
• 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
4.4 Are 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. Medium risk: the authority's powers are not always used in all the relevant Effective Implementation (I)
TOTAL 3
Radio Description Yes No NA MD
4.1 Does 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 ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is 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. X
4.3 Does 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;
• 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
4.4 Are 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. Medium risk: the authority's powers are not always used in all the relevant Effective Implementation (I)
TOTAL 3
Print Description Yes No NA MD
4.1 Does 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 ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is 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. X
4.3 Does 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;
• 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
4.4 Are 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. High risk: the relevant authority never uses its sanctioning powers X Effective Implementation (I)
TOTAL 2 2
Online Description Yes No NA MD
4.1 Does 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 ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is 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. X
4.3 Does 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;
• 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
4.4 Are 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. High risk: the relevant authority never uses its sanctioning powers X Effective Implementation (I)
TOTAL 2 2

Cross-Media Ownership Concentration

This indicator, originally, assesses the concentration of ownership in the different sectors (across TV – Print – Radio – Online). Concentration is measured by adding and weighting the market shares of the Top 8 owners across all sectors in which they are operating. However, as the market shares were not available for media market in Turkey, instead Cross-Media Audience Ownership was calculated according to the audience shares.

The results presented here are not indicators for economic strength in different media sectors but rather indicators for the potential influence on public opinion when considering all media types. The cross-media audience shares were calculated according to the influence of different media sectors on the public in Turkey.

According to a media consumption research conducted by DataWise 2017 , 73% of the population watch TV (at least one hour per day), 39% read daily newspapers (at least 1 newspaper per week) and 10% listen to the radio (at least one hour per day), %44 of society use internet at least one hour per day.

 The top four owners of media in Turkey share approximately % 71 of the cross-media audience in the country which results in a high risk. They have investments in at least three media sectors.

Turkuvaz / Kalyon Group (30%) have investments in all four sectors. The second one is Ciner Group (15%) which has investments in only TV and online market after the Group closed its print media (Habertürk) in 2018 It has 15% of weighted audience share.

Although Demirören Group has investments in all four sectors, as the Group does not publicize the audience shares of its online news portals, MoM Turkey couldn’t count it  to calculate the impact on the audience shares. Despite having no audience share data for its online news portal, Demirören Group became the third larger company in Turkey with a weighted audience share of 15%. The Doğuş Group is the fourth with the %11 of the audience share.

They are followed by Estetik Yayıncılık (Sözcü Daily and website - 10), Hayat Görsel Yayıncılık (Kanal 7, Radyo 7, haber7.com - 10%),State owned TRT (9%) and Türk Medya (5%) in terms of the weighted audience shares. 

MEDIA CONSUMPTION
Internet 44%
Television 73%
Print 39%
Radio 10%

Percentage % 71 (HIGH)

LOW (1) If within one country the major 8 owners (Top8) have an audience share below 50% across the different media sectors.

MEDIUM (2) If within one country the major 8 owners (Top8) have an audience share between 50% and 69% across the different media sectors.

HIGH (3) If within one country the major 8 owners (Top8) have an audience share above 70% across the different media sectors.

DataWise: Türkiye’de medya tüketim trendleri

Regulatory Safeguards: Cross-Media Ownership Concentration

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.

The media legislation contains specific limits. The same company can only provide one radio, one television and one on demand broadcast service, and a real person or a legal entity can directly or indirectly hold shares in a maximum of four media service providers. However, in the event a real person or legal entity holds shares in more than one media service provider, the annual total commercial communication income of media service providers in which a real person or a legal entity is a direct or indirect shareholder cannot exceed thirty per cent of the total commercial communication income of the media sector.

There is no specific regulation on digital media and printed press; therefore these mediums' concentration is subject to Competition Authority. The law grants both authorities sanctioning and enforcement powers in case of a breach.

Competition Authority shares its decisions as well as the knowledge and experience accumulated with the public regularly. However, Supreme Council's decisions on concentration of media service providers are not public; therefore monitoring whether media service providers notified Supreme Council for a share transfer or not is no possible to determine.

Radio and Television Supreme Council is the authority for the regulation and supervision of radio, television and on demand media services, and has sanctioning and enforcement powers. According the Law, the same company can only provide one radio, one television and one on demand broadcast service, and a real person or a legal entity can directly or indirectly hold shares in a maximum of four media service providers. Though there is not a specific regulation on digital media and printed press, both are subject to Law on the Protection of Competition.

Cross-Media Ownership Description Yes No NA MD
5.1 Does 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
5.2 Is 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
5.3 Does 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
5.4 Are these sanctioning/enforcement powers effectively used? the relevant authority never uses its sanctioning powers Low risk: the relevant authority effectively uses its sanctioning powers in all the relevant cases
The question aims at assessing the effectiveness of the remedies provided by the regulation. Medium risk: the authority's powers are not always used in all the relevant
High risk: the relevant authority never uses its sanctioning powers
5.5 Can 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 the competition 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);
Even though the law does not contain media-specific provisions - it,does not exclude the media sector from its scope of application
X
5.6 Is 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
5.7 Does 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 carry obligation to give up licences/activities in other media sectors;
- divestiture.
X
5.8 Are these sanctioning/enforcement powers effectively used? The question aims at assessing the effectiveness of the remedies of the regulation. Low risk: the relevant authority effectively uses its sanctioning powers in all the relevant cases
Medium risk: the authority's powers are not always used in all the relevant cases
High risk: the relevant authority never uses its sanctioning powers
Total (Mean of L-e und L-I sub-indicators)

Ownership Transparency

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

Media company owners and their shares can be found most of the time in the Trade Registry Gazette archive on ticaretsicil.gov.tr. The archive can be searched by names of companies. However many of the media outlets have companies as their only shareholder, so to reach the name of an actual person it can be necessary to go through a bunch of connected companies in the trade registry.

The name search function in the chamber's search motor only shows the Board of Directors the person is a member of and (unless a company is a 'Limited') doesn't show which companies they own shares in. To find this, the only way is to learn the name of the company and dig through its records in the Trade Registry Gazette.

Some of the old records can't be opened online using the Trade Registry Gazette, so it's impossible to reach information on the shareholders if the shares haven't been changed for a long time.

Political affiliations of media owners, meanwhile, can usually be reached through research. However, in some cases -such as that of Doğuş Media and Doğan Media - political affiliations of media owners/executives have come to light through wiretaps or leaked correspondance that were claimed to be between owners/executives and government officials. These records showed how media outlets that looked like they had little to do with the government, except for non-media related activities, were actually controlled by the government, through direct conversations/correspondance between government officials and media owners/executives.

The government has been involved in the take over and sale of media outlets. The Insurance and Savings Deposit Fund (TMSF) has taken over and sold many outlets under the AKP regime due to "collecting of debts." Meanwhile, the details the sale of Turkey's largest satellite tv platform, Digiturk, has not been made public. The Qatar based company beIN Media Group has purchased the platform from TMSF for an "undisclosed amount."

LOW (1) MEDIUM (2) HIGH (3)
TRANSPARENCY
6.1 How would you assess the transparency and accessibility of data about the media ownership?
Data on media owners as well as their political affiliations is publicly available and transparent.
(Active Transparency)
Data of media owners and their political affiliations are disclosed based on investigations of journalists and media activists or upon request.
(Passive Transparency, Data Publicity Available)
Data on political affiliation of media owners are not easily accessible by the public and investigative journalists or activists are not successful in disclosing these data.
(Data Unavailable, Active Disguise)
Code if that applies to >75 % of the sample. Code if that applies to >50% of the sample. Code if data is available for < 50% of the sample.

Regulatory Safeguards: Ownership Transparency

In Turkey media service providers who have been granted a broadcasting license are obliged to notify the Supreme Council of the information on the names and surnames of the shareholders, its shareholding structure and the vote proportions subsequent to the share transfer within a period of thirty days as of the validation date of such transfer. Additionally media service providers are obliged to publish information on (i) the name of the company, (ii) its correspondence address, telephone and email address, (iii) its logo/call sign, (iv) their broadcasting license and broadcasting networks, (v) the name, surname and contract information of its accountable manager in an up-to-date manner in their websites and notify such information to the Supreme Council. Even though the information is available in Trade Registry Gazette, the law does not oblige media service providers to publish their ownership structure on their website.

Thus this indicator is assessed as medium.

Transparency Provisions Description Yes No NA MD
7.1 Does 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. X Existence (E)
7.2 Does 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. X
7.3 Is 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. X
7.4 Are 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. X Effective
Implementation (I)
7.5 Do 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. Low Risk:
All the effective owners are known by the public
Medium Risk:
Some owners are still unknown
High Risk:
Effective owners are still hidden
Total (Mean of L-e und L-I sub-indicators)

(Political) Control Over Media Outlets and Distribution Networks

This indicator aims to assess the risk of political affiliations and control over media and distribution networks. It examines the transparency of data about the political affiliations of media owners, the proportion of specific political affiliation of media owners across the media market in terms of audience share. It also assesses the level of discrimination by politically affiliated media distribution networks.

Owners of media that support the government have been reported as acquiring rights to build large public projects such as the third airport (Kalyon Group which owns Turkuvaz Media) and the Galataport project (Dogus Group).

Ethem Sancak, (owner of the BMC which manufactures TOMA, the water cannon vehicle for the General Directorate of Security Affairs, and armored personal carries for the Turkish Armed Forces) sold its media assets (known as ES Medya) to Zeki Yeşildağ whose brother (Hasan Yeşildağ) has close ties with President Erdoğan. ES Medya is now known as Türk Medya (T Medya Yatırım San. ve Tic. A.Ş).

Calculation shows more than 70% of media owners in Turkey are affiliated with the ruling party. (See Business Interests, Political Affiliations and Individual Owners).

Print Distribution:

The two largest print distribution companies in Turkey, Yaysat (owned by Demirören Group) and Turkuvaz (owned by Kalyon), are owned by media groups. There is no inspection into the operations of these companies, which makes the amount of media they print and distribute questionable.

According to the online news portal Odatv.com, Demirören Group has decided to shut down of Yaysat (the Publication Company of Demirören) on October 31, 2018. This story was published via ODATV at first, it was also circulated through other media outlets. If the allegations that Demirören Group decided to close the Yaysat were correct, the print media will only be distributed by Turkuvaz Medya of Kalyon Group. However, Demirören Group neither confirmed nor refuted this claim.

TV and Radio Distribution:

Radio and Television Supreme Council is the authority for the regulation and supervision of radio, television and on demand media services, and has sanctioning and enforcement powers. The first wave of decisions shutdown 16 televisions and 23 radios following the coup attempt in July 2016. In September 2016 RTUK has shut down 12 more television channels and 11 radios. The reason was stated as being members of a terrorist organization, however the shutdown included Kurdish cartoon channel Zarok TV and Alevi channel TV 10.

The decrees declared during the state of emergency, brought the shutdowns of 38 TVs. This includes the decisions to shut down by RTÜK (19 TV channels).

Digiturk and D-Smart are the largest owners of digital TV distribution networks. Digiturk was taken over by the government from Cukurova Group in 2013 due to "collection of debt," after which it was sold to Qatar based beIN Media Group. Digiturk has removed Gulenist affiliated TV channels from its platform in 2015, after the rift between the Gulenist movement and the AKP government began.

Score: 16/21

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

What is the share of TV media owned by politically affiliated entities? Result: 45%

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 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 channels owned by politically affiliated entities? Result: 42%
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 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.
8.3 What is the share of Newspapers owned by politically affiliated entities? Result: 52%
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 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.
8.4 What is the share of Online Media owned by politically affiliated entities? Result: 73%
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 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.
POLITICATION OF MEDIA DISTRIBUTION NETWORKS
8.5 How 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
8.6 How would you assess the conduct of the leading radio 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
8.7 How 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

Sözeri C. (2015), İktidarın Çarkında Medya
Ethem Sancak Interview on 360 TV (2015)

(Political) Control Over Media Funding

This indicator assesses the influence of the state on the functioning of the media market, focusing particularly on the risk of discrimination in the distribution of state advertisements. The discrimination can be reflected in favouritism towards political parties or affiliates of political parties in the government, or in penalisation of media criticising the government.

State advertising should be understood as any advertising paid by governments (national, regional, local) and state-owned institutions and companies.

Results: 

There is no transparency on how much state advertising individual media outlets receive. The rules of distribution regarding state advertising are too vague and broad, thus criticized for not being fair.

An important source of income for newspapers - especially smaller and local papers -  is the public announcements and advertising handed out by the Press Advertising Institution (BİK). 

BİK has refused to answer a freedom of information request from RSF to disclose advertising handed out to newspapers in the past 12 months, stating that the information was a “trade secret”. Thus, it’s not possible to determine that the state advertising is distributed to media proportionately according to their audience share. 

Following the coup attempt, on October 5, 2016, regulations regarding BİK were changed. According to this contested regulation, any news outlet that employs a journalist who is being tried on terrorism related charges will not be given state advertising, unless the employee is fired from the media organization in five days.

 

LOW (1) MEDIUM (2) HIGH (3)
9.1 Is the state advertising distributed to media proportionately to their audience share? Impossible to assess.
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.
9.2 How would you assess the rules of distribution of state advertising?
State advertising is distributed to media outlets based on transparent rules. State advertising is distributed to media outlets based on a set of rules but it is unclear whether they are transparent. There are no rules regarding distribution of state advertising to media outlets or these
IMPORTANCE OF STATE ADVERTISING
9.3 What is the share of state advertising as part of the overall TV advertising market?

VALUE: MD
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
9.4 What is the share of state advertising as part of the overall Radio advertising market?

VALUE: MD
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.
9.5 What is the share of state advertising as part of the overall Newspaper advertising market?

VALUE: MD
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.

Tunc, A. (2015), Media Integrity Report
P24 (2016), Journalists in State of Emergency
Press Advertising Institution - Fundamentals for Media Principles, Retrieved October 16, 2016, from http://www.bik.gov.tr/basin-ahlak-esaslari/

(Political) Control Over News Agencies

The questions addressed to news agencies regarding their finances were left unanswered.

Anadolu Agency (AA) is a joint stock company which was founded by the state of Turkey. Its shares are owned by the Undersecretariat of Treasury. AA is the largest news agency in Turkey, with its structuring both inside and outside the country. The broadcasting of Anadolu Agency, like that of TRT, has been and is being criticized for being pro-government.

In 2011, 70 Turkish Journalist's Union (TGS) member employees of the agency were forced to retire and the positions of 52 TGS member employees were downgraded. A new union was formed by the agency, which has been criticized as "serving the employer." The appointment of Kemal Ozturk in 2011 and Şenol Kazancı in 2014 as the head of the agency, brought many staff dismissals from the agency.

Gulenist affiliated Cihan News Agency has been taken over by the government in March of 2016, and shut down after the coup attempt in July 2016.

DIHA, the Kurdish affiliated news agency, has been under government pressure for anti-government reporting especially regarding the clashes in the Southeast. DİHA was also shut down after the coup attempt. 10 DIHA reporters are imprisoned based on charges of support to terrorism or of being members of "terror organisation" PKK.

Based on the decrees 668, 675, 677, the number of news agency shut down reached 6 (Cihan Haber Ajansı, Muhabir Haber Ajansı, SEM Haber Ajansı, Dicle Haber Ajansı, Jin Haber Ajansı, Dihaber - Dicle Medya Haber Ajansı)  during the OHAL period.

LOW (1) MEDIUM (2) HIGH (3)
10.1 What is the market share of the leading news agency?
VALUE: MD
No news agency dominates the market (occupy >30% of the market of news agencies). One news agency has <50% ≥30% share of the market of news agencies. The leading news agency has ≥50% market share.
10.2 How would you evaluate the political affiliation and/or dependence of the largest news agency?
2 out of 3 leading news agencies are politically affiliated.
None of the largest news agencies is dependent on political groupings in terms of ownership, affiliation of key personnel or editorial policy. At least one of the largest news agencies is dependent on political groupings in terms of ownership, affiliation of key personnel or editorial policy. Most or all of the largest news agencies is dependent on political groupings in terms of ownership, affiliation of key personnel or editorial policy.

RSF - Government leaned on judicial system in media holding case, Retrieved October 16,2016

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