The Nine Network of Public Media (KETC) knows that a diverse workforce, management team, governing body, and Community Advisory Board contribute greatly to our knowledge and understanding of the region’s diverse communities, and to our ability to deliver content and services that will help us attract, grow and engage audiences and help them to achieve their full potential. We endeavor to recruit from a broad pool of candidates enabling us to hire and promote qualified candidates with a variety of cultural and ethnic backgrounds, personal experiences and characteristics, and talents that reasonably reflect the diverse needs and interests of the communities served by the Nine Network.
The Nine Network will continue to explore new opportunities for achieving and promoting this diversity and to monitor and evaluate our success. The means the Nine Network adopts and will always meet the standards of federal and state law, the Nine Network’s Equal Employment Opportunity Policy, and the Corporation for Public Broadcasting’s Diversity Eligibility Criteria.
This policy documents KETC-TV’s (“Nine Network”) compliance with Section 396(k)(11) of the Communications Act of 1934, as amended, (the “Act”) that sets forth the equal employment opportunity requirements that are applicable to public broadcasting stations (codified at 47 U.S.C. Section 396(k)(11)) and the Diversity Requirement contained in the Corporation for Public Broadcasting’s (“CPB’s) Television Community Service Grant General Provisions and Eligibility Criteria (the “General Provisions”).
Section 396(k)(11) of the Act prohibits CPB from distributing its federally appropriated funds to any public broadcasting station with more than five full-time employees that has not filed with CPB an annual statistical report that: (a) identifies by race and sex the number of employees in each of eight full-time and part-time job categories (officials and managers; professionals; technicians; semi-skilled operatives; skilled craft persons; clerical and office personnel; unskilled operatives; and service workers); and (b) states the number of job openings occurring during the course of the year. This Section of the Act also requires that this statistical information be made available to the public at the main business office of the station and at every location where more than five full-time employees are regularly assigned to work.
Additionally, Section 396(k)(11) requires that each public broadcasting station that receives a Community Service Grant (“CSG”) from CPB certify to CPB that the station complies with Federal Communications Commission (“FCC”) regulations concerning equal employment opportunity or any successor regulations. Each public broadcast station licensee with more than five full-time employees must also certify that the job openings identified in the statistical reports described above were filled in accordance with such FCC regulations, or provide a statement of the reasons for not filling the positions in accordance with such regulations.
The Diversity Requirement in the General Provisions requires that each CSG grantee station adopt, annually review, and make necessary revisions to a diversity goal for its workforce, management and boards, including community advisory boards and governing boards having governance responsibilities specific to or limited to the public broadcasting station.
Under the Diversity Requirement, each public broadcasting station must also annually review with the station’s governing board or licensee official: the diversity goal and any revisions thereto; and practices designed to fulfill the station’s commitment to diversity and to meet applicable FCC regulations.
Further, each public broadcasting station must maintain on its website, and annually update, a diversity statement that addresses: the elements of diversity that the station finds important to its public media work; the extent to which station’s staff and governance reflect such diversity; the progress the station
has made to increase its diversity in the last two to three years; and the station’s diversity plans for the coming year.
Finally, each CSG recipient station must undertake one of the following initiatives on an annual basis:
1. Include individuals representing the diverse groups served by Grantee for internships or work-study programs, which must be designed to provide meaningful professional-level experience and further public broadcasting’s commitment to education;
2. Include qualified diverse candidates in any slate of individuals considered for positions on elected governing boards that Grantee controls;
3. Provide diversity training for members of Licensee’s governing body or board of directors;
4. Participate in minority or other diversity job fairs; or
5. Provide diversity training for management and appropriate staff.
As the licensee of KETC-TV, St. Louis Regional Public Media, Inc. receives a CSG for the operation of KETC-TV. All CSG grantees, including St. Louis Regional Public Media, Inc., must annually certify at the beginning of CPB’s fiscal year that they are compliant with the public broadcasting provisions of the Act and CPB’s General Provisions in order to receive their CSG.
This policy will improve the reliability of St. Louis Regional Public Media, Inc.’s certification that KETC-TV complies with the provisions of 47 U.S.C. Section 396(k)(11) and the Diversity Requirement in the General Provisions.
Policy & Procedures
KETC-TV will comply with the provisions of 47 U.S.C. Section 396(k)(11). KETC-TV will comply with all Federal, state and local laws, as well as FCC regulations and its own human resources policies, concerning equal employment opportunity and non-discrimination.
KETC-TV will file annually with CPB the statistical report described above and will certify that the job openings identified in the statistical report were filled in accordance with FCC regulations or provide a statement of the reasons for not filling the positions in accordance with such regulations.
KETC-TV will make this statistical information available to the public its main offices, located at 3655 Olive Street, St, Louis, MO 63108-3601, and at any other location where more than five full-time employees of KETC-TV are regularly assigned to work. This statistical information is contained in the Station Activities Survey (“SAS”) that KETC-TV submits to CPB each year. As such, KETC-TV will make the employment statistical information contained in KETC-TV’s SAS report available to the public. This same SAS information will remain publicly available for three years after the spending period for the CSG requiring compliance concludes.
A photocopy of the employment statistical information described in the preceding paragraph will be provided to any member of the public requesting the report. The photocopy will be available for pick up by the person requesting it at the address listed in the previous paragraph.
It is the goal of KETC-TV to have a workforce, management, governing board, and advisory boards that are diverse and reflective of the communities that KETC-TV serves. KETC-TV management will annually review this diversity goal with its governing board and make revisions to the diversity goal that the governing board and management deem to be necessary. KETC-TV management will also annually review with its governing board KETC-TV’s practices that are designed to fulfill the station’s commitment to diversity and to meet the applicable FCC equal employment opportunity regulations.
KETC-TV will post, and annually update, on the ninenet.org website a diversity statement that meets all of the requirements contained in the General Provisions. KETC-TV will also participate in at least one of the annual initiatives listed in the Diversity Requirement in the General Provisions.
KETC-TV understands that CPB strongly encourages each CSG grantee to interview at least one qualified diversity candidate for each senior leadership position hire. The term “senior leadership position” includes: Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Chief Content Officer, General Manager, and other equivalent positions. KETC-TV will endeavor to include such candidates in its interview process for senior leadership positions.
KETC-TV will maintain documentation evidencing compliance with this policy, including screenshots of the material posted on the Website, for three years after the spending period for the CSG requiring compliance concludes.
The Nine Network of Public Media (KETC-TV) primary broadcast signal area encompasses the bi-state St. Louis MO-IL Metropolitan Statistical Area (MSA), which includes 7 Missouri counties (St. Louis, St. Charles, Franklin, Jefferson, Lincoln, Warren and Washington), the City of St. Louis, and 8 Illinois counties (Bond, Calhoun, Clinton, Jersey, Macoupin, Madison, Monroe and St. Clair). The MSA has a resident population of approximately 2.8 million according to population estimates from the U.S Census Bureau. While the Nine Network’s reach through its broadcast signal, cable and satellite extends beyond the MSA to span approximately 100 predominately rural counties in Missouri and Illinois, the MSA represents the primary center of population, the majority of Nine’s viewership, and the only source of Nine Network staff and board.
Following are the statistics that gauge our community’s diversity as compared to the diversity of Nine Network of Public Media workforce.
Ethnicity: MO-IL MSA Nine Network
White 77% 79%
Black or African American 18% 18%
All Other 5% 3%
Female 52% 63%
Male 48% 37%
On a historical basis, over a two-year period, Nine Network 2016 minority employment was 21.0% compared to 24.3% and 25.8% for 2015 and 2014 respectively.
Following are the statistics that gauge our community’s diversity as compared to the diversity of Nine Network of Public Media board of directors.
Ethnicity: MO-IL MSA Nine Network
White 77% 93%
Black or African American 18% 7%
All Other 5% 0%
Female 52% 36%
Male 48% 64%