SECTOR 1 1.11 Media legislation evolves from a meaningful consultation among state institutions, citizens and interest groups Although consultations were held during the drafting of the Communication Code, not all stakeholders were involved in the process. For example, the National Consumer Defense Network (RNDC), trade union organisations and some members of the press were not invited. As part of the consultations on the amendments to the Communication Code, regional consultation workshops were held in the period from June to July 2019 in the following provinces: Mahajanga, Toamasina, Antananarivo, Antsirabe, Antsiranana, Fianarantsoa and Toliara. A widely distributed announcement was made, not only to media professionals, but also to the general public. However, many of the opinions expressed at these workshops were not included in the text forwarded to the Council of Ministers.23 This is believed to be due to time constraints. The workshops were carried out in an expeditious arrangement and there was not enough time for reflection. The voiced opinions were not included in the text forwarded to the Council of Ministers. Scores: Individual scores: 1 Country does not meet indicator 2 Country meets only a few aspects of indicator 3 Country meets some aspects of indicator 4 Country meets most aspects of indicator 5 Country meets all aspects of the indicator ✓ ✓ ✓✓ ✓✓✓✓✓ ✓✓ ✓ Average score: Score of previous years: 1.5 2006: n/a; 2008: n/a; 2010: 2.3; 2012: 2.1; 2016: 2.1 Overall Score for Sector 1: 2.7 23 Many recommendations were made during the regional workshops. For example, participants asked that the Order of Journalists of Madagascar (OJM) no longer be integrated into the provisions of the text, in the logic of a gradual shift towards the establishment of a trade-union. However, the OJM would still occupy a preponderant place in the regulation of the exercise of professional journalism, in particular as regards ethics and professional conduct, and especially through the disciplinary council. The chapter on image rights also crystallised all the criticisms. The participants recommended that it should be amended according to the very principle of the journalist’s fact-finding mission. However, these recommendations were not considered. The criminal sanctions provided by the new article 20 are heavy in the event of invasion of privacy and the right to image. 21 AFRICAN MEDIA BAROMETER MADAGASCAR 2019