Monitoring of the media reporting on the party – political and inter-ethnic issues during the pre-electoral period - Project supported by the Embassy of the Kingdom of the Netherlands and the OSCE Mission in Skopje SECOND REPORT From the Watchdog Mechanism of the Media Reporting at the UNESCO Chair on Media, Dialogue and Mutual Understanding (March 3 - 14) What is the watchdog mechanism? The overall objective of the Watchdog Mechanism is to provide rapid detection of all media articles/broadcasts which can create an atmosphere of serious tensions in the political and inter-ethnic relations, or which can promote speech that can cause violence, intolerance and discrimination, negative stereotypes, as well as hidden or open calls for violent mobilization. It is important to note that these examples are only part of the observed violations of the legislation and professional standards in the selected period and that similar or milder types of violations appear in other media outlets as well. Only the most characteristic and noticeable violations are listed and analyzed here, which clearly illustrate the type of violation that can be found in many other texts. Hence, the research team and the expert panel do not intend to impose ethical sanctions to the newsrooms of the indicated media outlets by emphasizing these examples. Instead, the objective is to encourage them to think about the negative role that the media can have in the disintegration of the society, either through careless or deliberate reporting that encourages stereotypes, prejudices, divisions and intolerance. The aim of the School with this Project is to help the professional journalistic community in trying to preserve ethical and professional principles and values and the reputation and dignity of the profession. How does the Mechanism function? The Mechanism is consisted of a group of selected and trained analysts who monitor the media, a research team of the School who makes the selection and conducts a qualitative analysis of the texts, and a panel of experts that reviews and discusses the submitted materials and it analyzes and decides on the content of the reaction that the Chair should release in the public. The Watchdog mechanism operates under a clearly defined procedure that has four consecutive stages: 1 Selection and alerts: The analysts monitor the content in the media that have been identified and allocate all texts related to the elections and the interethnic issues, according to a detailed set of guidelines. Then, they inform the research team about possible violations, by stating the name of the media, the date and title of the published text. Analysis: The team selects and conducts a qualitative analysis of the journalistic articles and items, and determines whether they contain violations of the legal framework and the professional standards. Expert panel: The expert panel, consisting of external professors and experts from several universities and organizations partners of the UNESCO Chair, meets and discusses on the qualitative analysis and the highlighted violations and decide on the final version of the analysis and the contents of the reaction to be released. Public reaction: The expert panel may decide to immediately react (if violations are significant) or to act cumulatively (to violations in texts that are accumulated over a longer period). Media included in the monitoring The monitoring included only professional media that publish daily news and information. Their selection is made according to the impact they can have on the audience, i.e. according to the data on the number of viewers, readers and listeners. Daily newspapers: Dnevnik, Vecer, Utrinski vesnik, Nova Makedonija, Fokus, Koha and Lajm Radio stations: Macedonian Radio 1, Kanal 77, Macedonian Radio 2 (Albanian language) TV stations: MTV 1, MTV 2 (Albanian), Sitel, Kanal5, Telma, Alfa, TV 24, Alsat M Online: Plus Info, Kurir and Portalb In the print and online media, analysts monitor all texts related to the elections in any section they are located (Elections, Macedonia, Economy, etc.). In the electronic media, analysts monitor the prime time news and they analyze the news items related to the internal political developments and the election campaign. Contents of the Second report This report summarizes the assessment of the media coverage in the period from March 3 to 14. The most common deviations observed from the professional standards in this period refer to three points: (1) hate speech and inflammatory speech; (2) discrimination or stereotyping of an ethnic group; (3) negative speech directed at individuals and marginalized groups. General conclusions are given at the beginning of each point for the most noticeable and most common deviations from the professional standards, and in the next part, media and examples of texts/articles are listed in a chronological order where deviations were observed. An overview of the violated international and national professional standards is provided at the end of the document. The analysts sent alerts for 210 texts and news items in the observed period and the qualitative analysis included 101 out of them. 2 1. General conclusions from the monitoring The analysis showed that in most cases when hate speech or inflammatory speech in the media is identified it is related with transferred statements of politicians, columnists and other opinion-makers in Macedonia. The strongest inflammatory messages in this period were transferred speeches of politicians who participate in the party's election campaign. Regardless of that, the newsrooms cannot distance from their own responsibility for the effects and consequences that this speech can have on the interethnic relations. The media have an obligation to severely condemn hate speech, especially when it could have serious consequences for the inter-ethnic relations. Even in exceptional cases, when it comes to explicit and extreme hate speech, the media outlets have a right and a duty to refuse to publish the speech. Politicians should be condemned without exception at every attempt to spread hate speech and inflammatory speech, expressed in or out of the election campaign, which they do in order to win more votes or to be more attractive to the electorate. Statements that are full of hatred, intolerance, stereotypes and divide citizens along ethnic, religious or other grounds, make an enormous damage to the country's democratic processes. When it comes to multi-ethnic and multi-religious country such as Macedonia, politicians need to be aware of the effect that their statements cause among all citizens of Macedonia, and not only among those that they directly address. Political leaders bear a huge responsibility for the fact that in this period speeches are spread through the media that can have serious consequences for the interethnic coexistence. 2. Explicit hate speech and inflammatory speech During this period, several articles were published in some media where press releases, views and attitudes of political parties, organizations or individuals were transmitted without any distance and contextualization, which "introduce" themes for alleged "ethnic cleansing of Albanians" in Skopje", for the “anti-Albanian Macedonian state policy" and even for the alleged "religious anti-Albanian propaganda" being conducted by the Macedonian state. The dominant inflammatory speech comes from the political parties, which in the struggle for political rating, "play" with the national feelings of citizens. Some media, when reporting on the violence that occurred after the protests in Skopje and subsequently in several high schools or in buses, recklessly underlined the ethnic background of the participants in the violence, either attackers or victims. It can further increase anxiety and impatience among citizens. Portalb, 03.03.2013: „Ilirikum Libertas: An ethnic cleansing occurs in Macedonia“ The online media text publishes a press release of the NGO Ilirikum Libertas which reacts with a call to the international community to influence "the Macedonian part of the government" on the occasion of the violence that took place after protests organized against the appointment of Talat Xhaferi. In the press release the violence is verbally identified as "ethnic cleansing of Albanians" in Skopje, and additionally instead of the country's constitutional name the reference "FYROM" is used. The inflammatory effect of this press release is additionally enhanced with the visualization (an image of a bleeding boy) and with the headline. The responsibility of the media is that it does not distance itself from this press release, instead being a carrier of an ethnically corrosive message. „The organization Ilirik Libertas sharply reacts to, as they say, the last campaign of ethnic cleansing of Albanians from several districts of the FYROM capital, Skopje ... This is a politics that is culminating several times in recent years with an aggressive campaign against young Albanians, ethnic cleansing and segregation in certain areas, even to physical elimination of the more emancipated patriotic elements of our community. 3 Telma, 5.03.2013: „Incidents in Skopje with an inter-ethnic connotation“ The news item, which in part is re-broadcasted from Alsat M, informs of an attacked underage schoolgirl from the school "Dimitar Vlahov". The injured student is partially quoted in which the ethnic background of the alleged attackers is stated. It is disputable that the statement is framed in ethnic terms, although the attackers were unidentified. Additionally, the news item reports about two other similar incidents and in both cases it emphasizes the ethnic background of the attacked, identifying them as Macedonians. In this way, it implicitly states the ethnicity of the attackers as well. "They were skinny and tall guys with masks on their faces. They spoke in Macedonian language. I no longer can “normally” go to school; I am under a lot of stress. I think other students are scared as well. I appeal to all not to repeat such horrible things, Arlinda Bajrami told Alsat M yesterday. Yesterday evening two similar incidents occurred in Skopje. Dozen unidentified persons attacked 24-year-old boy from Macedonian nationality at around 7:30 pm, near the Bit Pazar. They punched him and caused visible injuries all over his body. Two hours later, three unidentified persons attacked a 35-year-old citizen from Skopje, close to the Macedonian National Theatre, also of Macedonian nationality.” Similar violation was made by Telma on 6.03.2013. This a priori framing of the incidents in an ethnic connotation does not allow the possibility that perhaps all these incidents are motivated by different reasons, not ethnic ones. In this way, the medium demonstrates that there is a pre-designed horizon of expectation of the events. Kanal 5 TV, 05.03.2013: „Albanians care only for their people, and they are silent about the Macedonians“ The television, in its prime time news programme, broadcasts an interview with a political analyst. In the cue of the interview and the video graphic it is written: "Albanians care only for their people and they are silent about the Macedonians." This sentence makes a contrast between the Albanians and Macedonians, constructing them as monolithic ethnic categories. Additionally, it makes a negative stereotyping of the Albanians as an ethnic group that is concerned only for "their people" and is insensitive to the Other. Koha, 6.03.2013: „Religious Anti-albanian propaganda“ (column) The column, in which the last year's fivefold murder at Smilkovci is re-contextualized in a framework in which the tragic event is staged by the state of Macedonia in order to blame "Albanians" understood as a monolithic group, is an example of a strong and explicit inflammatory speech that can trigger new ethnic tensions, especially in the context of the events associated with the current preelection campaign. Regardless of the fact that the column is a view expressed by an external analyst, the medium undoubtedly bears a responsibility when it transmits such a strong inflammatory speech: „Thirteen-year old Albanian child from Skopje does not accept to kiss the cross and it is beaten and face cut with a knife by Macedonian hooligans, and this is an act whose consequences are beyond a single incident ..... it is a reflection of the real anti-Albanian politics through which the Macedonian state tries to portray the Albanians as Islamic extremists. It is the best tactic to avoid international reactions even in the cases when young Albanians, bystanders, are brutally beaten, yet in the presence of police, who seems to enjoy the event. "Last year, it was well considered how to benefit from the murder of the five young Macedonians, killed by their country Macedonia, which tried to alert the world in a perfect way that Albanian terrorists kill young Macedonians to make a severe harm to the Albanians." Lajm, 07.03.2013: „The tensions in Macedonia are caused by Serbia and ‘remnants of the past“ This text covers attitudes of an analyst from Kosovo (Adem Demaci) who gives an interpretation of the violence that occurred after the protests on the occasion of the appointment of Talat Xhaferi, and of several other subsequent events for which the media reports were contradictory and insufficiently checked. The journalist did not distance himself from the views of the analyst that places these events 4 in the context of a broader radical scenario for Macedonian-Serbian conspiracy against Albanians. By establishing this symbolic link between the "Serbs" and "Macedonians" who are framed as carriers of evil and who are against the Albanians" portrayed as victims, the attitudes of the quoted analyst are not challenged at all and this produces an inflammatory speech. „The Macedonian police remnants, together with their counterparts Serbs, masked, with their barbaric actions, want to scare the Albanians by beating children, face cutting the students and with other actions aimed at encouraging Albanians to open wounds and new fronts. According to him, the Albanians in Macedonia should be careful not to become a prey of these scenarios. 'They should not behave like the Macedonian criminals and the Serbian agents with whom they interact ..." Portalb, 08.03.2013: „DPA in Celopek: Let’s stop the ethnic cleansing of Albanians with your voice“ This text covers a speech by Menduh Taci at a rally in Celopek. He called the citizens from this part to massively vote for his party in order to “stop the ethnic cleansing in the City of Skopoje”. The medium has to challenge the statements of politicians who spread an inflammatory speech with their own counter-argument. „The current Government aims to ethnically clean the City of Skopje. I call on Albanians to vote to stop the ethnic cleansing of the Albanian cities. If such politics continues, the same situation will occur in Tetovo, equally as in Skopje," DPA leader Taci said. Koha, 08.03 .2013: „Have some more mercy for the Albanians in Skopje“ This text is a report which makes an overview of the actions of Albanian political party representatives in the pre-election campaign. Pieces from the candidate’s speeches are extracted in most of the text, in which they talk about community issues and topics that affect citizens. However, part of the text quotes a political statement by a DPA list holder (Idriz Orana), which implies the existence of a “Macedonian national” politics that strategically places Albanians in “ghettoized” neighborhoods. „The Macedonian national strategy, supported and approved by DUI in the Government structures, is to ultimately integrate the country in the EU with ghettoized Albanian neighborhoods. The Albanian settlements in Skopje are same as the ghettos in the 30’s and as the reservations of the 19th century… thus Europe will get the impression that Albanians are fans of the primitive and miserable lifestyle. Look at the other part, where Macedonians live, it has an exactly a Western look”, Orana said. MTV 2, 08.03.2013: A news item is broadcasted in the Albanian language current news programme at 6:30 pm, on the occasion of March 8th, which talks about the present position of the Albanian woman in Macedonia, where quotes from several women are presented. It turns out that from the spectrum of quoted statements the Albanian woman can be everything “from a teacher to a soldier”, as one woman identifies herself as a former member of the KLA forces. The simple transfer of this statement, without its contextualization in today’s social context, can provoke anxiety and intolerance among citizens: „I fired a whole round of bullets at the enemy, who harassed and tortured my people in the last few years. The best gift I got was a gun by the co-fighters at the Kosara Mountain, Skodrane says, a woman, former soldier of KLA, at the celebration of the International Women’s Day in the Theater of the Albanian drama......Skodrane’s speech was euphorically welcomed by the attendees.“ 5 Sitel, 11.03.2013: „Ljubanci is waiting for the hero“ The character of Johan Tarculovski is glorified, which in several parts of the news item, including the cue and the video graphics is claimed to be a "hero" and a "victim". The word "victim" is mentioned in the headlines, the cue of the news item, and several times in the news item, resounding as a main thread in which the object of observation is framed. The choice of statements by several citizens tendentiously contextualizes Tarculovski as one of the heroes of the Ilinden epic, especially with the statement that says that "Tarculovski is Goce Delcev". The rest of the story is absent, or the view of those who do not perceive Tarculovski in this light. A feature of the inclusive journalism in societies such as the Macedonian is to present the reality comprehensively, especially when the events have an inter-ethnic connotation. Vecer, 12.03.2013 – „Ljubanci is waiting for its komita“1 A similar effect is caused in Vecer’s article from this date - the same information is reported in the spirit of Tarculovski’s glorification. The word "hero" in the headline is replaced by the term "komita", which has a very positive connotation for the Macedonian ethnic community. In fact, the expression komita is used to name remarkable persons from the national history who fought for the Macedonian issue, for the liberation of the Macedonians and for the constitution of their own state. „Ljubanci is a village in which everyone believes in the innocence of Tarculovski. His photographs are in the neighborhood stores. He is an icon for the people of this village. - After Goce Delcev, he is the greatest hero of Macedonia, people from Ljubanci would say, if you ask them whether they perceive him as a hero. " 2. Discrimination or stereotyping of an ethnic group A major problem in the reporting of numerous media is the fact that texts are completely used from other media or social networks as a source of information, which consist unconfirmed information on sensitive inter-ethnic issues. The practice of so-called “copy-paste” journalism is particularly dangerous at a time when unchecked information make a negative stereotyping of ethnic groups and this may further deepen the inter-ethnic tensions after the violence associated with the protests, in the high schools and in several buses. In addition, with the "simple" transfer of politicians’ speeches in the election campaign, in which they mutually accuse as "traitors" to their ethnic group, the media outlets enter the trap of uncritical and reckless spreading of the negative stereotyping on ethnic grounds. Dnevnik, 04.03.2013: „Abusive graffiti in Struga“ The newspaper uncritically covers a press release of the news agency in Albanian language (INA) which says that graffiti from unknown persons were drawn at the building of the Centre for Social Work in Struga, which implies that the motives for the graffiti is the violence that followed after the protests in Skopje. It is unclear how the motives of people who are "unknown" are identified. "Irritated and annoyed by the recent events in which young Albanians were brutally beaten, unknown persons wrote graffiti at the building of the Center for Social Work in Struga, where there was a series of remarks and disagreements these days due to the non-use of the Albanian language by the staff, thus breaking the Law for the official use of the Albanian language. They wrote the following content: 'Down with fascism', "'The Albanians are those who are beaten and these whores do not care about that, the Agency INA reported." 1 A “komita” is a 19th and 20th century Macedonian rebel fighter against the Ottoman Empire. 6 Plusinfo, 04.03.2013: „Grafitti in Albanian all over Struga“ Plusinfo took the news from Dnevnik in which the press release from INA is transferred, which also uncritically covers unconfirmed information that implies that "yet unknown persons" were "annoyed and irritated" by the events in Skopje. In addition, the text headline stereotypically associates the language of the ethnic group with the unscrupulous behavior of those who wrote graffiti around the city. „Struga woke up this morning with graffiti written in Albanian, Dnevnik reports. The Agency INA reported that "irritated and annoyed by the recent events in which, as noted, young Albanians were brutally beaten, unknown persons wrote graffiti at the building of the Center for Social Work in Struga, where there was a series of remarks and disagreements these days due to the non-use of the Albanian language by the staff, thus breaking the Law for the official use of the Albanian language. They wrote the following content: 'Down with fascism', "'The Albanians are those who are beaten and the main whores do not care about that, the agency INA reported." Alfa TV, 05.03.2013: „DPA: Instead of protecting the Albanians, DUI named them as hooligans“ Although the harsh rhetoric in which political parties often exchange aggressive words is usual during the pre-election period, still in some cases this rhetoric can cause serious consequences for the interethnic relations. DPA's political speech in this case demonizes the assumed political opponent, but at the same time it creates a discourse of victimization of the Albanian community in which DUI is a collaborator. This demonizes DUI as a treacherous organization of the Albanians and at the same time the narrative for the Albanians solely as victims is re-affirmed. The speech of the representative of the political party is not challenged at all. „While the Albanians were beaten, tortured and left without any support these days, DUI and Ali Ahmeti did not even try to protect them," DPA MP Bekim Fazliu accused today. Fokus, 07.03.2013: „Religious weekend wars scheduled over Facebook“ In the Focus article the medium justifiably warns about what happens on social networks. However, what is problematic here is the headline of the text, which qualifies the violence that occurred after the protests on the occasion of the appointment of Talat Xhaferi as a Defence Minister with a religious dimension. Thus, this is overemphasized or re-contextualized in a potential inter-religious conflict from the inter-ethnic one, by using extremely inflammatory terms. The problem with this headline is the sensational approach of the author who played with the resonance while setting the three words which begin with the same letter “religious weekend - wars [...]” (verski vikend vojni), but caused the effect of a threat that has a religious character. The choice of a style of writing is certainly right of the author of the journalistic articles, but the journalist has to take into account the meaning that might have inflammatory effects. The headline of the article is also published at the front page of the newspaper, which gives even greater weight of this violation. Dnevnik, 13.03.2013: „The Romas and Turks will decide – Macedonian or Albanian“ This article is published on the front page of Dnevnik, occupying almost the entire space, thus indicating about the importance of the contents of the text. It has a sensational headline which abuses the ethnic background of the voters in favor of the political battle. The headline ethnically “ranks” the voters, thus the social and political space is constructed as a battle of ethno-collectivities and not as a battle of ideas. At the same time, the headline reinforces the perception of ethnic division and grouping in Kicevo, which itself can lead to further fueling of the inter-ethnic tensions. There is a speech in the text which reinforces the ethnic division in the city: „The Albanian political block harshly reacted to this (the joint coalition) with an explanation that the Macedonians, although a minority in the new Kicevo municipality, seriously struggle for the mayor’s position, and in this way they make a 7 majorization of the Albanian population again ... After the merger of the four municipalities towards Kichevo the ethnic picture is changed in favor of the Albanians ... " 3. Negative speech towards individuals or marginalized groups During this period, some media outlets uncritically covered the statement of the candidate for a mayor Aleksandar Petreski in which he offends entire marginalized group. These media outlets did not criticize and challenge the insulting and discriminatory speech by Petreski. Several online media reported in this way as well, but they are not covered by this monitoring. We indicate only examples of media outlets which are included in the monitoring and where this violation was identified. Plusinfo, 05.03.2013: „Petreski: I am not a queer, he is free to fall in love with him if he wants to“ „They say I fell asleep at the meeting with Bandini, whose close people said they were in love with him. I am not a queer, he is free to fall in love with him if he wants to. And they even said: I am so ashamed for this. With God’s permission, both Ohrid and Macedonia will be saved,” Petreski said. Vecer, 06.03.2013: „I am not a queer to have Bandini’son from Sutka2 to fall in love with me “ The newspaper is apparently trying to approach the statement of the candidate for a mayor of Ohrid Aleksandar Petreski with sarcasm, but even with the introductory sentence it induces a strong stereotype for the gays as "perverts". ..„ The citizens of Ohrid understood that they do not have a pervert mayor, he openly spoke in front of few people who went to the square at the last night’s rally. Aleksandar Petreski spoke about his sexual orientation in front of his fellow citizens insteadof promising projects." The stereotyping and discrimination of a sexual minority and vulnerable groups is often a transferred discourse of politicians. However, the media outlets are responsible to provide a critical distance from such speeches and to condemn them. If the journalists decides to cover this speech, he has to make a critical distance and to provide a particular context. The non-criticized transfer of the Petreski’s statement in this case reinforces his message and creates a platform for such a speech. Nova Makedonija, 14.03.2013: „Everyone is a quiet observer as the idea for a Greater Albania enters the campaign“ The text makes a violation of the standards by publishing of a photograph showing a child whose face is clearly visible. Thus, his identity is misused in ethno-political context. The medium has a special responsibility when it comes to posting information or photographs of vulnerable groups (children, youth under 18, people with disabilities, elderly people, people who have suffered an accident, etc.).. 2 Sutka is a settlement in Skopje mostly populated with Roma people 8 5. Overview of the international and national professional standards Article 10 of the European Convention on Human Rights „Everyone has the right to freedom of expression. This right includes freedom to hold opinions and freedom to receive and send information and ideas…The exercise of these freedoms…may be subject to…restrictions or sanctions…in the interests of national security, territorial integrity or public safety, the prevention of disorder or crime…” Recommendation (97)20 on „hate speech“ Hate speech is “..all forms of expression which spread, incite, promote or justify racial hatred, xenophobia, anti-Semitism or other forms of hatred based on intolerance, including intolerance expressed by aggressive nationalism and ethnocentrism, discrimination and hostility toward minorities, immigrants and people with immigrant backgrounds”. Principle 1: ... public authorities and public institutions at national, regional and local level, as well as official servants, have a special responsibility to refrain from statements, particularly for the media, which could be understood as hate speech, or speech that is likely to produce the effect of legitimizing, spreading or promoting racial hatred, xenophobia, anti-Semitism or other forms of discrimination or hatred based on intolerance. Such statements should be prohibited and publicly rejected whenever they appear. Code of Journalists of Macedonia General principles: „A basic task of journalists is to respect truth…journalists should be honest, impartial and accurate. It is the right and obliagation of journalists is to seek to prevent censorship and distortion of news… journalists shall defend human rights, dignity and freedom, will respect the pluralism of ideas and attitudes ... " Article 10 „The journalists shall not intentionally endanger the human rights and freedoms….shall not speak with the language with the language of hatred and shall not encourage violence and discrimination on any ground (national, religious, racial, sexual, social, linguistic, sexual orientation, political).” Article 14:„The coverage of political processes, particularly during elections, should be unbiased and balanced. The journalist must set a professional distance from the political actors”. Legislation of the Republic of Macedonia Article 68 of the Law on Broadcasting, Article 8, 9 and 10 of the Rules of Conduct for broadcasters in the period before the start of the election campaign and Article 9 of the Rules of equal media presentation during the election campaign. Article 69 of the Law on Broadcasting: „ Programmes are not allowed in the public broadcasters aimed at stirring national, racial, gender or religious hatred and intolerance”. .“... Code of Principles of Conduct of Journalists (International Federation of Journalists) „Journalists should be aware of the danger of inciting discrimination through the media and should make every effort to avoid discrimination through the media and should make every effort to avoid discrimination based on race, sex, sexual orientation, language, religion, political or other opinion and national and social origin”. Impartial and accurate informing – stories that are comprehensive, without ignoring the important facts; tendency to avoid biased reporting; refusing pejorative terms; a space for valid and logical disagreement; giving an opportunity to respond to those who are attacked; intransigence toward the influence of the commercial and political interests. Humanity and solidarity – doing no direct and intentional damage to others; minimizing harm; being open minded and thoughtful; having due regard for the rights of the public and the moral quality of journalism. " 9 BBC editorial guidelines Section 4, Impartiality: „Impartiality lies and it is in the core of the BBC’s commitment to its audience... News in whatever form must be treated with due impartiality, giving due weight to events, opinion and main strands of argument... „ Section 10, Politics, public policy and polls: „The principles related to our political impartiality…are central in our reporting on politics and public policy…we must give due weight to all main strands of argument and to all parties….We should not make a campaign, neither allow us to be used for campaign’s purpose”. Ethical Journalism Initiative of the International Federation of Journalists „Journalists should avoid outside interests or commitments which could damage their reputation for impartiality, fairness and integrity…High profile journalists – such as popular presenters of television programmes or leading newspaper columnists – particularly need to be seen as impartial. 10