Commentary by SE “IBMPU” on the false publication of NGL.media about the company’s performance

On November 4, the NGL.media website published in its news section an article signed by investigator Yelyzaveta Chyp about the performance of the state-owned enterprise “International Broadcasting Multimedia Platform of Ukraine”, namely the assessment and development strategy and mentoring of the English-language YouTube channel The Gaze. In our opinion, the material contains inaccurate and incomplete information, has signs of manipulation, violates a number of journalistic standards, misleading the public and the media, and causes reputational damage to both the Ukrainian international broadcasting initiative and our partners from the SubSub company.

Before commenting on the content of the publication, we consider it necessary to draw the attention of the public and the media to the fact that neither the SE “IBMPU” nor SubSub LLC received any requests from NGL.media for comments or any other information about the subject of the publication. This led to the fact that the material of Yelyzaveta Chyp did not reflect the point of view of the Enterprise and our partners, and, unfortunately, revealed the incomplete knowledge of the author of the “news” about the company SubSub and the services it provides, and her lack of understanding of the pricing mechanisms for the services ordered by the SE “IBMPU”. It is even more surprising that NGL.media did not address the SE “IBMPU” with a corresponding request, since the launch of the digital platform The Gaze has regularly published various materials about its operation, addressed the Enterprise on this issue and always received both information on the substance of its requests and feedback from the SE “IBMPU” after the publications.

After all the journalist from NGL.media could have obtained and used the information that reveals the tasks of SubSub in auditing and mentoring The Gaze YouTube channel and makes their purpose and pricing mechanism transparent and understandable, even without contacting the SE “IBMPU” or SubSub LLC, as this information is available in the tender documents posted in the public domain in the electronic public procurement system Prozorro. Unfortunately, for reasons unknown to us, this was not done either. Also, in our opinion, this omission cannot be explained by the need to promptly prepare a socially significant news item, since the final information about this tender (Service Agreement No. 235/0810/24 of October 8, 2024) was published on Prozorro on October 9, 2024, and the news on the NGL.media website appeared on November 4, 2024.

As for the substance of the NGL.media’s publication, we can share the following:

1. Conducting a qualitative audit of The Gaze YouTube channel was one of the recommendations of the State Audit Service of Ukraine mentioned in the SASU report. In particular, the SASU recommended “reviewing the Concept of Content and Promotion of the Digital Platform of the State Enterprise “International Broadcasting Multimedia Platform of Ukraine” for the information needs of foreign audiences”.

Accordingly, the State Enterprise “IBMPU” decided to “ensure a high-quality audit of The Gaze YouTube channel, develop a new strategy for its development, content and promotion, as well as provide mentoring support for the effective implementation of the strategy in order to increase the efficiency and compliance of the platform with the stated goals”, for which purpose it attracted a reputable company with experience in providing relevant services. To this end, the Enterprise announced a tender, the winner of which was SubSub LLC, a well-known domestic company that works with many participants in the Ukrainian media market, including in-depth audit of YouTube channels, development strategy and mentoring. For reasons of protecting the commercial secrecy of the partners, the State Enterprise “IBMPU” is not currently authorized to disclose information about the contractors of the SubSub company. The tender was announced on September 19, and the deadline for submitting proposals was September 27. SubSub LLC was the only bidder. At the same time, the company provided all the necessary information on the experience of providing the relevant services and confirmation of the level of competence, as well as the justification of pricing. We would also like to address the accusation that only SubSub LLC participated in the bidding: The State Enterprise “IBMPU”, as well as any other participant, has no influence on the number of companies that apply to participate in the bidding.

2. The publication of NGL.media, with reference to an unnamed representative of one of the Ukrainian TV channels, unfortunately, revealed ignorance or misunderstanding of the entire range of services provided by SubSub LLC, their specifics and pricing features, as well as misunderstanding of the features and subject of the analyzed procurement by the SE “IBMPU”. In particular, the NGL.media publication states: “Kyiv-based SubSub LLC is the developer of the SubBox service for analyzing and promoting channels on the YouTube video hosting service. A representative of one of the Ukrainian TV channels that also uses this service to analyze its content told NGL.media that the cost of an annual subscription to SubBox does not exceed UAH 70 thousand. According to him, the average cost of a comprehensive audit of a YouTube channel and recommendations for development does not exceed USD 1,000-1,500 (UAH 41-62 thousand).”

Firstly, we would like to point out that the SubBox service, which is also used by the SE “IBMPU” in its work, has nothing to do with the procurement of services for a comprehensive audit and development of a strategy for the development, content and promotion of the Customer’s English-language YouTube channel, as described by NGL.media. Accordingly, the comparison of these prices is incorrect and misleading.

Secondly, the cost of auditing a YouTube channel is determined not just by the word “audit” but by the depth of analysis, its technical, qualitative and quantitative characteristics, a detailed description of which is contained in Appendix 4 to the Tender Document published in the Prozorro electronic public procurement system. Unfortunately, neither the author of the publication nor the experts involved have likely read the document. Otherwise, their ideas about pricing in the digital analytics market look strange. The price of USD 1,000 to 1,500 mentioned by the unnamed NGL.media expert may indeed be relevant to the so-called quick analysis, known in the market as “checkout analysis.”

Instead, the agreement between the State Enterprise “IBMPU” and SubSub LLC provides for a comprehensive audit service, development of a concept for the development, content and promotion of the English-language YouTube channel The Gaze, which is being implemented in three stages:

  1. a comprehensive audit of the YouTube channel, including a comprehensive analysis of the current state of The Gaze, an assessment of the content’s compliance with the project goals, identification of the main competitors in the English-language market, qualitative and quantitative comparison of their content with The Gaze’s content; determination of ways to improve and development of recommendations;
  2. development and confirmation of an updated development strategy for The Gaze YouTube channel, which will include recommendations for in-depth work with the audience, development of a content strategy for 6 months, development of a promotion strategy;
  3. mentoring and support for the implementation of the strategy until December 25, 2024.

Therefore, we hope that market experts realize that the aforementioned range of services cannot cost USD 1,000-1,500 if we are talking about high-quality work and result-oriented approach.

It is worth mentioning that the contract with SubSub LLC is not to be paid for from the state budget of Ukraine, but rather from the funds earned by the State Enterprise “IBMPU” through monetization of YouTube channels that are part of the structure of state international broadcasting of Ukraine.

3. Regarding the assessment of the effectiveness of The Gaze, which NGL.media has not done for the first time, we would like to note that the State Enterprise “IBMPU” is always open to constructive criticism. We are convinced that an open discussion on the development of Ukrainian international broadcasting promotes constructive interaction between state and public institutions and strengthens the resilience of the Ukrainian media community. We fully understand and support the importance of institutions of public control over the use of state budget funds and other manifestations of civic activism in relation to the public sector. We do not in any way question NGL.media’s right to cover the activities of the State Enterprise “IBMPU”, to examine our media content or to assess its quality. Instead, we expect NGL.media to do so in a quality, constructive and responsible manner.

First of all, we would like to draw attention to the fact that over the year and a half of its operation, The Gaze has formed a core target audience, its viewing figures show dynamic growth (+10.3 thousand subscribers and 3.7 million views in the third quarter of this year), and the depth of content viewing is also steadily increasing. Twice in August, The Gaze’s content made it to YouTube trends. These results, in particular, are also recorded in the audit of SubSub LLC. We do not seek to compare The Gaze and Kyiv Independent YouTube channels, as we support the idea that Ukraine’s voice should be represented as widely as possible on various media platforms. However, since NGL.media made this comparison, citing the Kyiv Independent as a successful example, we would like to note that since February 17, 2022, the Kyiv Independent YouTube channel has accumulated 93.6 thousand subscribers and 13.6 million views, and The Gaze YouTube channel has 35.8 thousand subscribers and 8.2 million views since May 17, 2023. Given the world’s intense attention to Russia’s full-scale invasion of Ukraine in 2022, when the Kyiv Independent YouTube channel was launched, we consider these figures to be quite comparable.

The publication also includes a commentary by media manager Yevhen Safonov, who believes that “no matter how much money the SE “IBMPU” spends on traffic, it will not increase its popularity. In this case, experts recommend starting another channel.” Of course, Mr. Safonov’s opinion has the right to exist and be implemented within the framework of the projects he is in charge of. However, the state enterprise received professional recommendations, given the formed core of the target audience, the dynamics of subscriber growth, the number and depth of views, to continue developing The Gaze brand in accordance with the updated strategy.

Dear colleagues, with this commentary, we want to convey to the public and the media the reasoned position of the State Enterprise “IBMPU” regarding our work and provide more complete and accurate information about Ukrainian international broadcasting, in particular The Gaze YouTube channel; demonstrate our commitment to the principles of open dialogue with the expert community. The State Enterprise “IBMPU” is open to cooperation with the media and counts on a balanced and unbiased attitude of the media to its activities. We appeal to NGL.media and other media outlets that published the news of November 4 with a request to publish our commentary in full, without changes, in the same section where the NGL.media material was published.