Ukraine, along with the Diderot Committee and the Union of Ukrainians in France, has filed a complaint with Arcom regarding interviews with EU-sanctioned individuals conducted by French media outlets—including the interview with Sergey Lavrov on France 2 and France Info. Legally, EU Regulation 269/2014 prohibits the provision of economic resources to sanctioned individuals: the interview itself constitutes such provision, regardless of any commercial agreement. Ukraine is requesting that Arcom intervene publicly, demand the withdrawal of the broadcast interviews, distribute the complete list of sanctioned individuals to French media and journalists, and consider financial penalties against the broadcasters involved.

Mr. President,

The broadcast of the interview with the Minister of Foreign Affairs of the Russian Federation by France 2 and France Info sparked a major wave of indignation and criticism.

Numerous observers, academics, journalists, public bodies, the European Commission, and the European Parliament consistently emphasize the importance of propaganda and disinformation in the Russian Federation's strategy of aggression against Ukraine and Europe. Giving a platform to the Foreign Minister of a state waging a terrorist and criminal war, at his request and under technical conditions that prevent the journalist from doing her job properly, demonstrates a lack of strategic foresight, professionalism, and ethics.

Several experts have raised the general issue of the French media's susceptibility to Russian propaganda in terms of ethics (the pursuit of scoops, the race for ratings, even a fascination with power), lack of preparation, lack of collaboration with experts, technical constraints, and an overestimation of their ability to engage with a seasoned diplomat. These various analyses are interesting, but our approach is framed in legal terms, and we hope that Arcom will examine the entire process that led to its dissemination, the methods of the interview, and its circulation.

Our organizations strongly condemn the very principle of this interview.

We observe:

• That this interview (like previous interviews with sanctioned individuals) constitutes a circumvention of European sanctions through the provision of economic resources, prohibited by EU Regulation 2014/269. The interview itself already constitutes the provision of economic resources, but it seems likely that an agreement was reached allowing the Russian Ministry of Foreign Affairs free access to the video. As we demonstrate in point 6 of the attached note, the interview video is also being used, particularly at the initiative of Margarita Simonyan, director of ANO-TV Novosti and coordinator of international Kremlin propaganda, by other websites and social media accounts supporting Russian positions. France Télévisions has thus contributed to fueling the war propaganda machine not only in France, but also in Russia itself and throughout the rest of the world.

• That the principles of control over the broadcast in a delayed program and of honesty of information were not respected (presentation of the program as a live broadcast when it is a delayed edit, weak contextualization, repeated absence of criticism of the false statements made by the Minister, absence of commentary by a qualified opponent)

• That the broadcast on the France Info website and its Youtube account of the entire interview, resulting from a demand by Minister Lavrov, constitutes a privilege granted to him, discriminating against other interviewees.

We also note the total absence of reciprocity: in the current circumstances of information control in Russia, it is obviously inconceivable that a French, Ukrainian or European leader could address the Russian population during an hour of prime time.

We support the approach of Mr. Laurent Mazaury, who, in the letter he sent you on March 27, requests that Arcom examine this sequence and, if necessary, initiate the procedures provided for so that this kind of event does not happen again in the future.

In addition to the arguments put forward by Mr. Mazaury, we would like Arcom to examine the broadcasts and their rebroadcasting on websites and social media accounts from the perspective of European sanctions as defined in Regulation 269/2014. The SREN law entrusted Arcom with the responsibility of ensuring compliance with these sanctions by French audiovisual services and telecommunications operators.

We therefore ask you to submit the attached report to the Arcom board and we request the Authority:

1. to intervene publicly to remind the media and journalists that, in accordance with European Union Regulation 269/2014, interviews with sanctioned individuals and their dissemination cannot take place at their initiative.

2. to request the removal by the media outlets cited of the interviews mentioned, which are accessible on their website or on their social media accounts.

3. to provide French media, journalists and operators with a list of all individuals sanctioned under Regulation 269/2014. This list is easily accessible on the European Union's EURLex website, but it is clear that many French professionals and journalists do not know how to use this official source of information.

4. to report to the European Commission the non-compliance by social network operators which, under the DSA, falls within its competence, with the sanctions against sanctioned propagandists (Russian or non-Russian), including when they accept that media accounts broadcast interviews carried out on their initiative with sanctioned individuals.

Our organizations are committed to freedom of information, journalists' rights, and public service broadcasting. In the case of Sergei Lavrov's interview, the fact that he appeared on two public service channels strikes us as particularly serious. More than any other broadcasters, public service broadcasters have a moral obligation to respect the law, both by virtue of their status, their mission, and their public funding.

We are aware of the efforts made by France Télévisions to report on the situation in Ukraine and to give its leaders a voice. However, we do not believe that public broadcasting, in order to fulfill its mission of informing the public, is obligated to establish a balance of airtime between the aggressor and the victim, especially when the aggressor is known for its capacity to resort to lies and disinformation. The so-called journalistic value of this interview is nil: Mr. Lavrov's statements revealed nothing new, particularly regarding his ability to deny the crimes of the regime for which he is partly responsible.

We invite the Authority to consider the possibility of a financial penalty against the broadcaster.

Thanking you for your attention, we ask you to accept, Mr. President, the expression of our distinguished greetings.

André Lange, Coordinator of the Diderot Committee

Jean-Pierre Patsernak, President of the Union of Ukrainians in France

Sylvie Rollet, President of For Ukraine, for their freedom and ours

Copy:

Ms. Constance Le Grip, Member of Parliament

Ms. Nathalie Loiseau, Chair of the European Parliament's "Democratic Shield" Committee

Mr. Laurent Mazaury, Member of Parliament

Ms. Delphine Ernotte, President of France Télévisions

Mr. Stéphane Sitbon Gomez, Director of Channels and Programs, France Télévisions

Mr. Jérôme Cathala, National Information Ombudsman for France-Télévisions.