Journalistic self-regulation: A more public-oriented model

Dr Rhonda Breit

University of Queensland

Refereed paper presented to the Journalism Education Conference, Griffith University, 29 November – 2 December 2005

Introduction
This paper reviews the system of journalistic self-regulation in Australia in terms of best practice in self-regulation. First it analyses a representative sample of journalism codes of ethics and codes of practice, classifying them according to their approaches self-regulation, the key characteristics of the codes, and the approaches to dispute resolution adopted. The findings of this analysis are then compared with best practice in self-regulation criteria distilled from the Taskforce into Industry Self-Regulation (2000a-f) to identify potential problems with the current scheme of journalistic self-regulation. Using the practice-institution schema, articulated by Breit (2004), further potential problems are identified. Finally, an alternative model of self-regulation is postulated that utilises the full range of dispute resolution techniques and targets the specific market failures confronting journalism in the 21st century. 
Journalistic self-regulation in Australia 
Journalism and the media industry in Australia are ‘regulated’ by a variety of organisations. The business arrangements and corporate dealings of media organisations are scrutinised by the Australian Securities and Investments Commission, the Australian Competition and Consumers Commission and state Offices of Fair Trading, which wield extensive legislative powers. The conduct of publishers and journalists employed in media organisations are scrutinised by industry-based self-regulatory bodies, which oversee a range of codes of ethics and codes of practice. This paper focuses on this complaints driven self-regulatory environment including the broadcasting regulator the newly formed Australian Communications and Media Authority (formerly the Australian Broadcasting Authority); the journalists union, the Media Entertainment Arts Alliance; and the voluntary print media regulator, the Australian Press Council. 
The Taskforce on Industry Self-Regulation, (Commonwealth of Australia, 2000a, 4) noted that self-regulatory schemes should be designed to address the nature and risk of market failure and the consequences of no action. Thus self-regulation can take many forms, including information campaigns, service charters, internal complaints handling departments and procedures, accreditation, licensing and membership certification, quality assurance systems, standards, codes and dispute resolution schemes (Commonwealth of Australia, 2000c, 3-5). Codes can be either institutional (industry) or functional (products or services that span more than one industry) (Commonwealth of Australia, 2000c, 3-5). The codes used across the media industry in Australia are institutional and functional, but in recent years there has been an increasing trend for workplaces to put in place their own codes. These organisational codes provide another layer to the self-regulatory environment as they aim to encourage socially responsible journalism and corporate behaviour. Organisational codes include those developed by the Australian Broadcasting Corporation (ABC), Special Broadcasting Service (SBS) as well as workplace codes used by The Age newspaper in Melbourne, the Sydney Morning Herald, and the Herald and Weekly Times, applying to all employees and contributors. The ABC and SBS codes set out in-house complaints procedures that are subject to review by the Australian Communications and Media Authority (formerly the ABA). 
The majority of organisations within the current system of journalistic self-regulation are not exclusively concerned with journalism. They oversee a range of related media industries. These organisations also oversee a range of industry-based codes. This study examined a sample of self-regulatory codes in order to classify their approach to journalism regulation. These codes include the MEAA (AJA) Code of Ethics, the APC Statement of Principles, the Free Television Codes of Practice, the Commercial Radio Codes of Practice, the ABC charter and statement of independence and the Internet Industry Association Codes of Practice. Table 1 (below) sets out the key characteristics of the journalism codes sampled for this study and the type of code they oversee. 

Table 1:  Summary of characteristics of professional codes in journalism 
Code	Definition of service ideal	Rules of conduct	Processes and procedures	Enforcement and review	
MEAA (AJA) Code of Ethics
Institutional	Yes	Yes	Yes (complaints procedure limited to application of rules)	Yes	
APC Principles
Institutional	Yes	Yes	Yes (negotiation and complaints) Internal review of rules 	Yes	
Free Television Codes of Practice (formerly FACTS)
Functional	Yes (limited to legislative objectives)	Yes	Yes (two stages)
Public consultation on code	Yes	
Commercial Radio Codes of Practce (formerly FARB)
Functional 	Yes (Limited to legislative objectives)	Yes	Yes (two stages)
Public consultation on codes	Yes	
ABC 
Organisational	Yes (Charter & independence)	Yes	Yes (three stages)
Public input on roles via many avenues	Yes	
Workplace codes e.g. The Age 
Organisational 	Yes	Yes	Not explicit (rules and ideology)	Not explicit	
The Internet Industry Association Codes of Practice
Functional	Yes.  Meeting legal requirements and responsible content delivery. No specific mention of journalism or news/current affairs.	Yes	Yes	Yes, codes reviewed annually. 	
With the exception of workplace codes, all self regulatory organisations set out procedures by which the codes can be enforced and reviewed. Given the Internet Industry Association Codes of Practice make no specific mention of journalism or the products of journalism – news and current affairs – they will not be included in the remainder of this analysis, which now maps the key dispute resolution techniques utilised within the self-regulatory scheme. 
Dispute resolution options
The National Alternative Dispute Resolution Advisory Council (NADRC) (AGPS 1997; Sourdin 2002, 16) classifies dispute resolution processes as facilitative, advisory or determinative. All three processes involve third parties but the type of involvement differs as follows:
facilitative processes: the third party plays no advisory or determinative role. Instead, they assist in managing the process of dispute resolution. Examples include mediation, conciliation and facilitation (Sourdin 2002, 16);
advisory processes: third party investigates and provides advice on the facts and possible outcomes of the dispute. Examples include investigation, case appraisal and dispute counselling (Sourdin 2002, 16); and
determinative processes: Third party investigates and determines outcome of dispute. Examples include adjudication and arbitration (Sourdin 2002, 16).
Sourdin (2002, 34) concludes that these processes can be classified as either decisional or facilitative, but many alternative dispute resolution (ADR) schemes include characteristics of both. She views the dispute resolution processes as a continuum – at one end is negotiation (which is the most often used form of ADR) and at the other end is arbitration which is the least used option. The bodies overseeing journalism and news and current affairs in Australia employ a range of processes and procedures, which Table 2 (below) classifies in terms of Sourdin’s continuum. 

Table 2:  ADR characteristics of journalism self-regulation
Code	Process
Stage one	
Stage two 	
Stage three	ADR 
classification	
MEAA	Mini trial			Determinative	
APC	Mediation with APC appointed mediator
Facilitative 	Adjudication, with some flexibility of process		Facilitative & determinative	
The Age	No procedure set out. No third party nominated to deal with complaints				
ACMA  (FreeTVA & CRA)	Negotiation with broadcaster. Broadcaster decides outcome (not third party) Facilitative 
Expert determination	Arbitration by ABA, with some flexibility in procedures
(determinative)		Facilitative and determinative (more determinative)	
ABC	Negotiation with ABC executive (not third party) Facilitative
Expert determination	Independent Complaints panel
Expert determination	ABA hearing
Arbitration with come flexibility of procedures	Determinative
& Facilitative 	
Table 2 reveals that although journalism is self-regulated by a variety of institutional, organisational and functional codes, the complaints processes adopted are essentially determinative. A limited range of facilitative methods are utilized in conjunction with determinative processes but advisory methods are not utilized. Thus the dispute resolution process sit at the extremes of Sourdin’s continuum, suggesting there is a need to incorporate advisory methods into the self-regulatory processes to help manage the dispute process and redress power imbalances between the self-regulatory bodies and the complainants. 
Best practice in self regulation
Good practice in self-regulation is built on two principles. First, the scheme must address the industry-specific problems and objectives and second it must offer an effective “minimum solution” (Commonwealth of Australia 2000f, 1). The minimum solution referred to by the Taskforce on Industry Self-Regulation is couched in terms of market needs -  “good practice in self-regulation can be understood as significantly improving market outcomes for consumers at the lowest cost to business” (Commonwealth of Australia 2000f, 1). To achieve these aims, industries should:
•	consult with industry, consumers and government ;
•	maximise scheme coverage;
•	ensure documents relating to the scheme are easily understood;
•	increase awareness of the scheme in terms of rights, obligations and duties and how to lodge complaints;
•	install a strong administrative body that can identify issues, collect data;
•	monitor the scheme, enhance credibility and monitor costs;
•	maintain data as indicators of systematic issues;
•	enhance transparency of processes and procedures;
•	include appropriate dispute resolutions to redress complaints;
•	include a range of sanctions;
•	manage risk of anti-competitive practices involved in scheme;
•	monitor and review the scheme; and
•	cost effectiveness (Commonwealth of Australia 2000f, pp1-24).
Table 3, depicted below, identifies the strengths and weaknesses in the current system of journalistic self-regulation based on the taskforce’s criteria. This table was developed from public documentation provided by the self-regulatory bodies and the Senate Select Committee’s recommendations. Therefore it reflects how the public would view the system of self-regulation.

Table 3:  Best practice characteristic of codes and MCC
Taskforce	MEAA	ACMA 	APC	Workplace codes	
Consultation	Formal review with public, media business, media owners, journalists and government	Formal & informal.
Journalists, public, media business, media owners, government. 	Formal & informal
Journalists, public, media business, media owners, government & complainants 	Informal with journalists, audience, media business and owners & complainants	
Coverage & publicity	Not well publicised except in relation to journalists	Well publicised to broadcast audience	Well publicised to print audience	Not well publicised, even to audience	
Awareness of scheme	Scheme not well publicised in media	Industry schemes required to publicise	Advertises to public
Sanctions involve publicity	Not well publicised	
Clarity of documentation	Journalists’ obligations clear. Consumer obligations not stated	Document very long & complicated. Legalistic language	Publishers’ obligations clear. Consumer obligations not stated	Journalists’ & managers’ obligations clear. Consumer obligations not stated	
Complaint scheme	Well publicised on website.	Well publicised
on TV, radio and Web sites	Well publicised in newspapers & website	Not well publicised but available on web search	
Education schemes	Poor	A focus of the new scheme 	Attempts to educate public and future journalists	Very poor	
Administration	No data collection that is available to public
Lack of transparency	Data maintained and reported to public via annual reports
Limited transparency	Data maintained and reported to public in annual reports
Limited transparency	No formal data maintained.
No real transparency	
Complaint handling procedures 	Closed hearing
Reports unavailable.	Public hearings
Reports available	Closed hearings
Public report	Closed process
Possibility for report (but at publishers’ discretion)	
Range of sanctions	Limited sanctions	Range of sanctions	Very limited sanctions	Sanctions not specified	
Monitoring & review	Formal reviews available 	Formal & informal	Formal & informal 	Informal	

This analysis suggests that the current system of self-regulation does not meet the common elements of good practice identified by the self-regulatory taskforce. There are a number of deficiencies. First, journalism and the media are compartmentalised, with individual organisations overseeing different aspects of the industry, such as print and broadcast. No one organisation can deal with every facet of journalism. Instead, organisations are structured in terms of the people they regulate and the product they oversee. Some organisations, such as the APC and to a lesser extent the ACMA, are highly transparent. Other organisations, such as the MEAA and workplace codes, are far less transparent. There are limited sanctions and penalties that can be imposed for breaches of code (across the broad spectrum of the scheme) and, as has already been noted, the full range of dispute resolution techniques has not been adopted. With the exception of the ACMA, the scheme has limited capacity to manage the risk of anti-competitive practices within journalism. 
Towards an alternative model 
In order to effectively design a system of journalistic self-regulation, the Taskforce on Industry Self Regulation argues you must be able to identify the industry the industry-specific problems confronting journalism, which means identifying the specific nature and risk of market failure.This paper does this by conceptualizing journalism as a social practice (Breit 2004a, b). The view of journalism as practice is derived from the practice/institution schema articulated by philosopher Alasdair MacIntryre in his book After Virtue (1985). When viewed in this way, journalism is one of a number of practices hosted by media corporations, which Breit (2004) describes as an institution. Breit (2004) also argues that self-regulation is part of the practice of media business i.e. integrating the goods of competing practices and a social practice in its own right. Thus self regulation is hosted by two institutions – the media corporation and organizations such as the ACMA, MEAA and APC. She (Breit 2004, 79) depicts the schema in the following way: 
Figure 1:  Journalism, media corporations  & self-regulation

Public

Practices of journalism, advertising and media business: all practices are hosted in the media corporation institution, but their relationship with the public sphere means they also are partially hosted by it. All also intersect with the practice and institution of self-regulation.

Self-regulatory bodies: Sits in public & private domains

Practice of self-regulation

Media corporation
Sits in both public & private domains

Audience & shareholder interests

Practice of media business

Practice of advertising

Practice:
Co-operative human activity
Intrinsic goods
Goals beyond profit
Striving for excellence
Transformation

The practice of journalism – to encourage ethical journalism the practice must position part of the ethical framework outside the institutions which host them.

	

This discussion reveals that two levels of self-regulation (institutional and organisational) operate within journalism. One is the practice of media business. The other is the practice of self-regulation. In the journalistic context, these practices are hosted by two institutions: the media corporations and the self-regulatory bodies. The internal goods of these practices are vulnerable to the external goods of these two institutions. But the practice of journalism and self-regulation are vulnerable to competing practices that are hosted by either media corporations or self-regulatory bodies. These vulnerabilities are the specific industry problems that must be addressed by a system of self-regulation. Thus when designing a system of journalistic self-regulation, attention must be paid to both levels of self-regulation in a systematic manner. The current scheme does address both levels of self-regulation, but the approach is ad hoc.

An alternative model of self-regulation
The aim in this paper so far has been twofold. First, I have sought to identify potential limitations arising from the current system of journalistic self-regulation by applying ‘best practice criteria’ derived from the Commonwealth Government Taskforce on Industry Self-Regulation. By using the practice-institution schema, I then identified the specific issues confronting journalism. Finally, I will offer an alternative model that meets best practice criteria while addressing the specific social policy and market issues confronting journalism. Specifically the alternative model seeks to address the vulnerability of journalism to external institutions and practices. The analysis so far has revealed the need for reform on three main levels: structural, procedural and educational.  
Procedural reform
The first area canvassed in this paper relates the processes and procedures employed to resolve disputes. These processes rely heavily of consumers or members of the public complaining about the conduct of a journalist (MEAA or workplace code), publisher (APC) or licensee (ACMA). Thus the scheme tends to be polarised into producers and consumers, without taking account of the range of potentially problematic relationships within the journalistic process. The scheme employs a limited range of dispute resolution techniques, which are located at the extreme ends of Sourdin’s dispute resolution continuum. Most of the dispute resolution techniques utilised by the media are decisional in nature. Limited use is made of facilitative and advisory processes are not employed. Thus the self-regulatory institutions maintain the greatest power within the scheme and complainants are invested with limited control. 
Structural reform 
More importantly, this paper has revealed a more fundamental problem with the current system that goes to the heart of the system: its failure to engage with the risks associated with market failures to take account of the vulnerability of journalism to external threats. This manifests itself in numerous ways. Journalistic self-regulation in Australia has tended to treat the public as passive recipients of information, rather than integral parties to the process. Therefore, the system has relied heavily on complaint-driven processes rather than considering the ethical obligations of audiences and the public in terms of consuming and interpreting information provided by journalists.
The practice/institution distinction reveals the process of self-regulation needs to be broadened to take account of corporate and business actions, not just the conduct of journalists and publishers. Media business practices are not obliged to comply with industry codes of ethics and practice. Their obligations are set out in the corporations and securities legislation as well as Trade Practice and Fair Trading provisions. One way in which media business can help reconcile the tension between the internal goods of journalism and the external goods of institutions is to introduce a system of corporate governance that commits to providing a diversity of views, multi-dimensional approaches to participation and upholding the values seen as hallmarks of journalistic excellence.
Based on this analysis, reform of journalistic self-regulation starts with the corporate governance programs of all media corporations. The imbalance between the goals of corporations and journalism also may be redressed to some extent by reconceptualising the measures of corporate success to include performance indicators that go beyond profit. In journalistic terms, this means including performance measures that look at the contribution to social participation not only audience needs and demands. When evaluating the quality of journalism, it is not enough to ask whether it complies with the code of ethics. The bodies overseeing journalistic ethics must ask the harder questions of whether the mediation processes (journalism and mass media) are fostering debate rather than controlling public opinion. Thus findings should be publicised and debated. 
The practice/institution distinction helps to illustrate that ethical reform of journalism in Australia will not be possible unless journalists, the organisations that employ them, the organisations appointed to oversee industry ethics and accountability as well as the public understand the potential weakening of practices when evaluated from the perspective of external goods of the institutions that host them i.e. the media organisations and the self-regulatory bodies. If journalism and media corporations continue to reinforce values like money, profit, audience and power as measures of the quality of journalism, journalism is devaluing itself. 
Educational reform
This analysis of the structural problems facing journalistic self-regulation reveals that part of the problem with the current system of journalistic self-regulation relates to the way in which the public is conceptualised as passive consumers of journalism. This suggests the need for comprehensive education programs that address public responsibilities in journalistic consumption. In addition changes are needed to the way in which journalists are educated. In addition to theoretical and practical training in journalists, attention needs to be paid to dispute resolution and ethics education of journalists and media business managers. Sourdin identifies (2002, 39) the foundation skills essential to people involved in effective dispute resolution. These include advanced listening skills and neutrality and impartiality (Sourdin 2002, 39, 44). She identifies broader dilemmas in relation to neutrality and impartiality which go to the integrity of the process, stating mediators must maintain the integrity of the process without violating the interests of the community and unrepresented parties. The legalistic and secretive processes and procedures adopted by the MEAA (AJA) Judiciary Committee do not engage with these issues. Despite recommendations by the Brennan Committee, the MEAA has opted to protect its own interests (legal safety) rather than reform its processes and procedures to reflect greater public transparency. Adjudications and findings need to be publicised, but in addition specialised training needs to be developed for media regulators. A review of the people involved in self-regulation of Australian journalism reveals the overwhelming majority come from management. Special attention needs to be given to balanced representation of journalism, the public, business and corporation/institutional concerns. 
This leads to the second issue, identified by Sourdin (2002, 44), which relates to maintaining equal bargaining power without compromising neutrality. It has already been noted that the current scheme invests the self-regulatory body with the greatest power whilst leaving complainants relatively powerless. The above model attempts to overcome these power imbalances by freeing the current bodies from their self-regulatory functions to represent the special interests of their stakeholders. They are therefore able to represent their stakeholder interests if a complaint is instituted or problem acted upon. You will note a body titled ‘public’ is identified to represent public interests. However, it is conceivable that ACMA should act for the public interest. 
Reviews of self-regulation such as the Taskforce into Industry Self-Regulation (2002) have linked the notion of accountability to business viability and it is here that the institutional aims of self-regulation offer the greatest potential for undermining journalistic virtues. Institutional self-regulation accepts that market considerations take a high priority when developing an accountability framework. In this way, market values are embedded in the language of self-regulation. This casts a further shadow on the values that underpin journalistic excellence, particularly where the industry views itself as a commodity. Where this occurs, market values dominate not only the media’s conception of journalism, but also what is seen as best practice in self-regulation. The ability of journalism to resist the erosion of journalistic values becomes less likely as market considerations are given further institutional recognition through the system of self-regulation. 
This discussion also has implications for journalism education. Both theoretical and practical skills must be incorporated within the journalism curriculum. But, more importantly, the collocation of practices within the corporate institutions suggests that ethics educators need to look more broadly than journalism. Aspects of business and corporate ethics should be incorporated into university curricula and practical ethics training. The public and consumers of journalism also need to be educated in ethics. This means involving the general public more in the self-regulatory and journalistic process. Discussions need to be held on what constitutes an ethical consumer of news. In addition, however, dispute resolution techniques should be canvassed in journalism ethics or media business management courses. It could be there is a need to develop postgraduate courses in media mediation and dispute resolution.
This discussion has revealed a number of other areas of reform, which are summarised in table 4 below: 

Structural	Procedural	Educational	
Role of business in self-regulation	Expand means of initiating process	Integrate theory & practice	
Variance in institutional & practice objectives	Expand range of ADR procedures especially advisory	Practice education for business managers	
Accommodating converging nature of journalism	Take part of process outside institutional framework	Dispute resolution training	
Incorporate public in process	Incorporate expert friends	Ethics education for mediators	
Market reform	Data collection	 Media literacy education for public 	
The model
Based on this analysis, this paper seeks to postulate an alternative model for journalistic self-regulation. Figure 2 attempts to map a holistic framework, which offers advisory, facilitative and determinative processes, while also taking account of the need for structural and educational reform.
Figure 4:  Alternative self-regulatory processes

Independent media

Advertising

ACMA

APC

MEAA

PRIA

Public

Internal review
Journalism & management representative

Problem

Independent mediator

Independent ethics advisor

Ethics officer

Media Ethics Commission
Includes representation from MEAA, APC, ABA, public, other media practices and the independent media. This bodies has a range of sanctions including punitive & facilitative

Complaint

The first point to make about this proposed alternative is that it is not complaint-driven. It offers two alternatives by which people can seek advice on problems with the media. These are through an ethics officer (which would be internal to the media corporation and selected from the ranks of practising journalists, someone who is not in a management position) and an independent ethics advisor (external to the practice and the institution). The ethics officer would offer advice and deal with problems and complaints internally. These problems could originate from within the organisation but he/she would also deal with complaints from members of the public. He/she would also be in charge of co-ordinating ethics education within the corporate environment. This offers a quick and simple method by which problems can be resolved without going into formal processes. Depending on the size of the organisation, it could be a workplace-based or corporation-based appointment. The ethics officer would compile data on complaints and ethical problems which should be reported to both the internal review panel and a Media Ethics Committee. The ethics officer should not be an editor.
The independent ethics advisor would be more of a policy advisor, who scrutinises the entire scheme and offers advice on difficult and complex issues, which may involve internal conflicts of interest, thus making the internal review process non-viable. This first-phase of the scheme is advisory.
The second phase of the scheme is a facilitative process which includes an internal review panel and independent mediators. The internal review team would comprise a flexible panel including representatives from journalism (an ethics officer or designate), management and the public. This panel would have limited powers such as printing corrections and requiring journalists and editorial decision-makers to attend ethics training. Complaints and problems also could be referred to independent mediators, who would be selected from a panel of expert media mediators.
The final phase of the review process sits with the Media Ethics Committee (MEC), which could adopt determinative processes where appropriate. The MEC would be a committee that reviews internal decisions. It could second representation from relevant workplaces, the public, practice experts and various industry bodies such as MEAA, APC, ABA and other media organisations. It would have the options of referring matters to the independent mediator and also to seek directions from the independent ethics advisor/s. This body would have a number of punitive sanctions available including fines, correction orders, publication of adjudications/findings and similar penalties. It would compile data on the media performance based on the reports received from media ethics officers and independent advisors.
Conclusions
The alternative model for journalistic self-regulation has a number of advantages in that it addresses the problems at the point of greatest influence: the workplace. Therefore it is more likely to influence how people perform their roles. So instead of promoting a compliant industry, the scheme is positioned to effect cultural change. It is not dependent on a complaint being instituted and it offers a framework to formally deal with internal ethical problems. It incorporates a range of dispute resolution processes, from advisory to determinative, offering a level of flexibility to align the process of resolution with the nature of the complaint. For instance, in relation to privacy and confidentiality matters, it may be better to deal with these issues confidentially through mediation than by determinative procedures that are open to public scrutiny.
The scheme also acknowledges the importance of education to maintaining ethical conduct. It acknowledges the need for comprehensive ethical training, which addresses the specific issues facing the practice of journalism. But such training needs to be holistic, engaging with ethical issues from the perspective of other practices and the institutions that host these practices as well as the general public. Any internal practice/institution-based education must be complemented by external education within universities and the general pubic. A multi-dimensional approach to media participation means educating members of the public about their responsibilities in an information society. This does not mean a code of ethics for members of the public, where sanctions can be imposed on consumers. It means engaging in debate, offering advice and reinforcing the view that consumption of news is not a passive activity. It is a dynamic process of reflective engagement, where individuals must convert information to knowledge to aid formation of a reflective public opinion. Universities play a major role in this and journalism education needs to maintain the trend of embedding skills training into a reflective context. 
The scheme also ensures a level of transparency because data relating to the conduct of journalism is maintained and reported to the public. By requiring ethics officers to collect data about complaints and ethical problems within the workplace and investing the MEC with a data collation and reporting function, this scheme offers a level of transparency that has not been available across sections of the current self-regulatory scheme. The ACMA performs these functions. The APC publicises details of complaints within the print media, but no similar data are available in relation to workplace complaints and those dealt with by the MEAA. 
Given the shift to a more convergent media regulatory framework, it is crucial that media ownership rules are reformed from an informed basis. Therefore a comprehensive analysis of political/cultural media market is needed before changes are implemented (although this is unlikely to occur). These data will offer people interested in journalism and business ethics rich sources of raw data that can be used to identify the specific ethical issues facing individual workplaces, media corporations as well as the industry. I see the introduction of a comprehensive reporting scheme, traversing all phases of the journalistic process, as the first step towards real ethical reform.
This is a reform model constructed on the specific problems facing Australian journalism. It does not presume to have solved the problems facing the journalism industry but it is a model grounded a theoretical schema that fully describes what journalism is. In this sense, it may help the industry beyond Australian shores to construct a system of self-regulation that recognises the central role played by journalism in contemporary society and the importance of encouraging reflective practice to ensure a greater understanding of journalism ethics.

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*Dr Rhonda Breit lectures in journalism law and ethics at the University of Queensland.