KHOI UNDERWRITING POLICY
Definition: Underwriting is defined as support for KHOI programming in the form of funds, goods, or services to KHOI that require KHOI, as a non-commercial educational (NCE) licensee, to identify its programs’ sponsors on the air in accordance with Section 317 of the Communications Act of 1934, as amended. Accordingly all underwriting support is considered a gift and shall be reviewed for acceptance in accordance with the guidelines stated later in this document.
The content and scheduling of these identifications must meet the provisions of Section 399 of the Act to ensure that they will not constitute impermissible advertising (as explained in the section below called On-Air Acknowledgement Guidelines).
A contractual agreement between KHOI and an underwriter explicitly does not confer the right upon the underwriter to influence station policy, content, or program selection (as explained in the section below called Editorial Freedom)
Underwriting KHOI is an opportunity for businesses and organizations and individuals to identify themselves with KHOI’s mission, which is to “Build community through communication.”
Non-commercial Mission: Underwriting acknowledgements are strictly for identification of KHOI supporters and are not promotional or commercial in nature. KHOI is a non-commercial educational (NCE) radio station licensed by the Federal Communications Commission.
Underwriting Rates: KHOI’s will establish underwriting rates. Rates will be reflective of the number of and placement of announcements. KHOI will establish a reduced rate from non-profit organizations. Underwriting rates will be provided in an information brochure given to interested parties. Nothing in the rate structure shall be construed as providing anything of value by KHOI or establishing a quid quo pro transaction between the donor and KHOI.
Length of underwriting contracts: After an initial contract period of no less than 3 months, all underwriting contracts will revert to be on-going, unless the underwriter and station manager agree on another arrangement. Contract periods of less than 3 months may be negotiated under special circumstances but will not be the rule.
If KHOI increases underwriting rates, existing contracts will not be affected until their initial contract periods expire. If the underwriter requests changes to an existing contract during the initial period, any new terms will be negotiated at the new rates. New contracts and contracts reverting to ongoing status will take effect at the new rates.
Changes to underwriting schedule: Occasionally, programming changes or other circumstances may make it necessary or desirable for KHOI to move an underwriter’s message(s) from one time slot to another. These instances are rare and KHOI will consult with the underwriter to discuss any such changes and their implications before making alterations. When KHOI initiates a change that impacts the rate structure of scheduled announcements, the following policies shall apply:
If KHOI initiates a move to a higher rated underwriting slot and the underwriter agrees to the change, he/she shall not be asked to provide the higher rate for the duration of the time remaining on the current contract, or in the case of an on-going contract, the current month. At the conclusion of these, he/she shall have the option to remain in the assigned slot and provide higher rates or move to a lower rated slot.
If KHOI initiates a move to a lower rated underwriting slot and the underwriter agrees to the change, KHOI will not refund any of the gift to the underwriter for the duration of the current contract or in the case of an ongoing contract, for the current month. KHOI will, provide the underwriter with additional late-night spots to fully acknowledge the underwriting contract. At the conclusion of the initial contract or current month of an ongoing contract, an underwriter may terminate support or extend the term of the scheduled announcements.
On-Air Acknowledgement Guidelines: Underwriting acknowledgement may be announced live by on-air programmers or, at the discretion of KHOI, be pre-recorded. They will begin with the phrase stating support for KHOI (such as “Support for KHOI comes from…”) from business, organizations, or individuals providing funds, goods, or services and will follow FCC guidelines for underwriting language.
Announcements may contain the following:
- Name of underwriter
- Underwriter’s address website and phone number
- Brand or trade name of the underwriter’s product or service
- Underwriter’s slogan, as long as it is not promotional
- Length of time the underwriter has been in business
- Value-neutral description of an event, service, or product provided by the underwriter
Announcements may not contain the following:
- Language that is clearly promotional in nature
- Comparative or qualitative language
- Non-identifying verbosity
- Any reference to cost, discounts, or financial incentives (including “free”)
- Calls to action
- Inducements to buy, sell, or lease
All underwriting messages will be limited to 15 seconds, including the introduction (i.e. “Support for KHOI comes from …”).
The KHOI underwriting brochure provides examples of permissible underwriting language. The Underwriting director will discuss all scripts with underwriters before airing them to ensure that they meet guidelines and also satisfy the underwriter.
An underwriting contract between KHOI and an underwriter specifies days and times at which the acknowledgements will air. KHOI will air underwriting messages at times and days so as not to interrupt regular programming, as stipulated in Section 399A of the Communications Act.
In accordance with this stipulation, KHOI reserves the right to air an underwriting message at a different time, but on the same day, as specified in the underwriting contract, if programming decisions necessitate such action.
Benefits to Underwriters: KHOI believes that the most significant benefit to its underwriters is listener recognition of the underwriters’ support for KHOI’s mission. KHOI also facilitates communication between listeners and underwriters by listing its underwriters on the KHOI web site (khoifm.org) with a contact number and/or a link to the underwriters’ sites, if they have one. KHOI will list underwriters at least once a year in its newsletter.
Editorial Independence: When accepting business sponsorship in the form of underwriting and contributions, KHOI uses the following guidelines for ensuring integrity and continuity of values. Our guidelines reflect our mission of free, sincere, and open public discourse. These obligations supersede personal, business, and institutional agendas. Our guidelines exist to assure our audiences that we adhere to editorial standards and that our services are free from undue or improper influence.
All underwriters must agree that their support of KHOI – regardless of level or duration of support – does not confer upon them any rights to influence the station policy, program selection, or content, either directly or indirectly. The underwriters’ signatures or that of their representatives on the underwriting contract will indicate acceptance of this policy.
To prevent influence by underwriters on station policy, programming, or practice, all underwriting will be consolidated into KHOI’s general budget and will not be credited to any specific program, activity, or event.
Potential underwriters will receive a copy of these underwriting policies in the KHOI information brochure and these will be stated in the underwriting contract.
KHOI Choice in Accepting Support: KHOI’s mission is to uphold and build the health and diversity of our local communities, and expand freedom of expression. KHOI selects underwriters to reflect these values. Our brand signifies commitment to responsible community development, so KHOI proactively seeks underwriters who are individuals, organizations, and businesses with core values of community, cultural development and who promote the common good. We seek to connect with those who:
- Engage in fair and equal treatment of all races, genders, sexual orientations, national origins, ages, religions, marital status, or mental disabilities
- Engage in fair labor practices
- Operate sustainably and plan for future generations’ needs
- Encourage human rights
- Respect and protect the environment
- Show and/or encourage local entrepreneurial initiative, local self-reliance and sustainability
- Support the local economy
- Provide for basic human needs at no profit
- Encourage and promote local arts and culture
- Provide local food
- Generate conditions for the flourishing of life and creative vision for our community
- Are judged upon reasonable evidence by KHOI to be engaged in activities that are socially responsible and congruent with the KHOI mission
KHOI reserves the right to refuse any funding support, goods or services that may be offered by individuals, businesses, or organizations.
Implementation: Underwriters will be solicited and communicated with by KHOI station manager or any staff person or volunteer assigned to do this. The person managing underwriting will follow the policy guidelines of KHOI. If a question arises regarding an underwriter, it should be resolved by the station manager. If any questions remain, the matter will be resolved by the KHOI board of directors.