Free Pick Up Copies - National Newspapers
Free Pick Up Copies (Regular)
Copies distributed on a regular and consistent basis to known distribution points for pick up or receipt by consumers.
Principles
1. Prior notification of distribution details and any changes to ABC
2. Distribution follows a regular and consistent pattern to known distribution points
3. Copies are made available at the known distribution points for pick up or receipt by consumers
4. Quantity claimed should not exceed potential demand by the intended consumers
5. Effective management controls over distribution
Requirements
1. Prior notification of distribution details and any changes to ABC
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You must obtain ABC’s agreement that your distribution system is capable of being compliant and verifiable to ABC standards before the distribution of the first issue for which you intend to claim pick up copies, including providing the following information with at least 14 days’ notice in advance of the planned distribution:
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Details of how, when and where the copies will be distributed
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A list of all distribution points.
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After initial approval of the distribution system, you must, on an on-going basis, notify ABC of any changes to the method of distribution or details on the master list of distribution points (such as changes in distribution quantities, distribution dates, new or ceased distribution points) as and when they occur.You must inform ABC before the distribution of the first issue for which you intend to claim pick up copies, including the following information.
2. Distribution follows a regular and consistent pattern to known distribution points
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A distribution point is defined as an agreed location at which copies are handed to or left for pick up by the consumer. Note:
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You must be able to provide the auditor with access to distribution points for verification purposes.
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A distribution point is defined at the micro level. For example: a single dispensing bin or single hand merchandiser as opposed to say a group of dispensing bins at a particular location.
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Only distribution points in the UK or Republic of Ireland can be claimed.
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The distribution points claimed must be consistent with the description or analysis reported.
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Gross distribution (i.e. supply) quantities must be broadly the same and to the same Distribution Points for all issues (except for permitted variations detailed in (c) below).
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The permitted temporary* variations in gross distribution (i.e. supply) quantities for an issue are as follows.
When compared to the previous ABC reporting period’s total average gross Free Pick Up distribution, an issue may be varied:-
For all titles:
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By up to 25%, without any stipulation or notification requirements.
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By greater than 25%, on an ad hoc basis as long as it is due to exceptional circumstances (for example due to tube strikes, severe weather) and ABC is notified within one month of the issue or before the claim is submitted to ABC (whichever is the sooner).
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By greater than 25% on a planned and regular basis to account for seasonal variations in the audience (for example a two week reduction in gross pick up copy distribution due to a holiday period). In this instance the publisher must notify ABC and include details of the seasonal change within any optional overview description for the affected Certificate.
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Only for publications published more frequently than weekly (e.g. daily):
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The gross distribution (i.e. supply quantity) may be varied without limit between different publication days/issues. For example: Mondays 10,000 copies, Tuesdays no copies, Wednesdays 5,000 copies etc
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If applying the permitted variation under points i) to iii) above you must compare the gross distribution for a Monday issue compared against the previous ABC reporting period’s total average Monday gross pick up distribution, same for Tuesdays, Wednesdays etc.
*If a change in distribution is permanent (i.e. will continue at that level for the foreseeable future) then these limits do not apply. -
For example: Daily title with different distributions on different days
Mon Tues Weds Thurs Fri Fee Pick Up Circulation Qty 10,000 0 5,000 0 20,000 Dist’n points City Centre - City Centre - City and Suburbs In this case, with the exception of ad hoc or seasonal variations:
10,000 for Mondays must be within 25% of total average free pick up for Mondays for previous ABC reporting period.
5,000 for Wednesdays must be within 25% of total average free pick up for Wednesdays on previous ABC reporting period.
20,000 for Fridays must be within 25% of total average free pick up for Fridays on previous ABC reporting period.
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3. Copies are made available at the known distribution points for pick up or receipt by consumers
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You must be able to provide evidence, from the third party responsible, of the number of copies of the publication made available for pick up or receipt at each distribution point by consumers. Note:
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Where the copies are made available for pick up or receipt at distribution points by drivers/distributors that are not 3rd party to the publisher (such as in-house distributors or from a joint venture), it may be possible to include these in the claim as long as:
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It can be demonstrated that the drivers/distributors have sufficient independence and are specifically contracted to deliver/distribute the publication.
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The auditor/ABC has full and unrestricted access to the relevant parties’ documentation and financial records.
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ABC has specifically agreed this distribution method.
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Where your ABC pick up claim is for the net number of copies picked up or received by consumers at a distribution point, you must be able to provide evidence of the number of copies returned/not picked up at each relevant distribution point.
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For publications other than dailies or Sundays, all copies must be delivered and made available within 24 hours of the majority of the rest of the distribution.
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You cannot claim distribution of back issues.
4. Quantity claimed should not exceed potential demand by the intended consumers
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Your ABC pick up claim must be reported as a minimum as follows:
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Daily and Sunday publications (except copies distributed airside and on trains): must be reported on a net basis (i.e. those made available less copies not picked up by consumers).
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Publications other than dailies or Sundays, and copies distributed airside and on trains: must be reported on a capped basis. (A capped basis means the number of copies claimed will be limited to designated caps at a particular location – see Caps by Supply Type section for details.
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5. Effective management controls over distribution
- The publisher is responsible for ensuring that the copies they claim have been delivered and if applicable returns/copies not picked up are accounted for. This requires a publisher to have appropriate management controls and processes in place to ensure that this is happening.
Reporting
You will report pick up copies as follows, which will be broken out on the ABC Certificate:
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By geographical type:
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United Kingdom
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Scotland – as a subset of UK
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England, Wales & N. Ireland – as a subset of UK
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Republic of Ireland (ROI)
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By total average pick-up copies per issue for the period, analysed as ‘Regular’ and broken into:
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Net distribution
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Capped distribution
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By issue/type, including for each:
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Description of distribution location/type and issue(s). Additional detail, such as number of distribution points, can be added as required.
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Quantity
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Note: Overall free circulation (regular and sample combined) in the Reporting Period cannot exceed the higher of:
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25,000 copies (average per issue); or
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5% of the total average circulation
Guidance
G1. Prior notification of distribution details to ABC
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The description of the distribution must be verifiable from evidence.
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The list of all distribution points. We would expect this to include the following for each distribution point:
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Unique point ID (to enable clear identification when changes are made).
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Address, including postcode.
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Audience Type. For example airside/international rail, hotel – as analysed on the Certificate.
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Whether there is a responsible individual based at the point, a deliverer places copies on display, or it is a hand distribution point.
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Point description. For example: type of bin, location at address.
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Point restrictions. For example it is particularly important to identify any points which can only be accessed via security barriers such as airport airside locations, some office buildings.
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Name of responsible person:
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Name of recipient for distribution points where individual based at point confirms delivery.
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Name of deliverer (in-house or name of delivery company) where deliverer confirms delivery.
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Telephone number of responsible individual.
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Normal day/date of delivery.
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Approximate time of delivery.
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Method of delivery. For example: in house, name of 3rd party distribution company.
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Normal supply quantity.
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Normal day/date of collection of returned/damaged copies (net copies only).
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Other information needed for audit typically will include:
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Issue by issue free pick up summary: This is an issue by issue summary of the claimed free pick up distribution compiled from the Detailed Issue Distribution Lists (see below).
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Detailed Issue Distribution List: This form includes on an issue by issue basis:
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Name/identification of distribution point
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Type of distribution point (e.g. hotel), manned or unmanned
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Gross supply
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For copies claimed on a net basis:Returned/damaged copies
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For copies claimed on a capped basis: the cap percentage or number
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Net distribution
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Actual day/date of delivery
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For copies claimed on a net basis: Actual day/date of collection of returned/damaged copies
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Copies that are purchased from distribution points are still eligible as pick up circulation as long as they comply with the pick-up rules.
G2. Distribution follows a regular and consistent pattern to known distribution points
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A distribution point is defined as an agreed location at which copies are handed to or left for pick up by the consumer.
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You should be able to provide details of the terms and conditions between the publisher and the distribution points for the supply and collection of copies, including any financial arrangements.
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- Examples of ineligible distribution (because it is not regular and consistent) include distribution to irregular exhibitions, rotational sampling, and variations in gross supply due to fluctuations in demand (except as allowed due to seasonal variation rules).
G3. Copies are made available at the known distribution points for pick up or receipt by consumer
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You must be able to provide evidence, from the third party responsible, of the number of copies made available for pick up or receipt at each distribution point by consumers.
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Typically, suitable evidence will be a delivery note signed and dated by a responsible third party individual (at the time of delivery) confirming the number of copies of the particular issue of the publication supplied and that they have made available for pick up or receipt at the particular location.
- Where the individual confirming the delivery is the driver/distributor, additional verification such as the deliverer’s manager signing to confirm completion, or the inclusion of a time of delivery may be required where ABC deems appropriate for audit purposes.
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If the evidence is from an individual that is not third party to the publisher (such as an in-house driver) then the records that additionally might be needed for audit could include run/route sheets, evidence of contractual arrangements, wage claims of distributor invoices.
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Ordinarily an individual based at the distribution point should be signing the delivery note at the time of the delivery. However if the signatory is unavailable at the time of delivery they can complete the delivery note left with the consignment and return to the publisher within 5 working days or before the distribution of the next issue (whichever is the sooner).
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With ABC’s agreement you may be able to maintain documentation on a team basis for a group of merchandisers or a group of dispensing racks at a designated location (for example at a train station).
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Where your ABC pick up claim is for the net number of copies picked up or received by consumers at a distribution point, you must be able to provide evidence of the number of copies returned/not picked up at each relevant distribution point.
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Typically, suitable evidence will be a returns note signed and dated by a responsible third party individual (at the time of collection) confirming the number of copies of the publication returned/not picked up, including the time collected. If there is no evidence you cannot assume 100% distribution but instead due to lack of evidence must treat distribution as zero.
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If the evidence is from an individual that is not third party to the publisher (such as an in-house driver) then the records that additionally might be needed for audit could include run/route sheets, evidence of contractual arrangements, wage claims of distributor invoices.
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Ordinarily an individual based at the distribution point should be signing the returns note at the time of the collection. However if the signatory is unavailable at the time of collection they can complete the returns/collection note left at the time of collection and return to the publisher within 5 working days or before the distribution of the next issue (whichever is the sooner).
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Distributors and their agents must not have a disincentive to accurately report the net number of copies picked up/received by consumers.
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With ABC’s agreement you may be able to maintain documentation on a team basis for a group of merchandisers or a group of dispensing racks at a designated location (for example at a train station).
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G4. Quantity claimed should not exceed potential demand by the intended consumers
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Where distribution claimed is limited by designated caps (see Caps by Supply Type section for details) you must have appropriate evidence to support the cap if applicable.
G5. Effective management controls over distribution
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For each publication the detail and extent of these controls and processes will vary as they should be appropriate to the type of distribution. These could include training of staff, spot checks, customer complaint handling etc.
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These controls and processes are reviewed by ABC as part of the joining process and continuing audit of a publication. These help underpin the audit in that they form part of the consideration of risk and consequently the type and extent of audit work done.
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If weaknesses in management controls are found during the audit work, the publication’s circulation auditor / ABC will inform the distributor and the publisher of defined improvements to be implemented and a timescale to ensure copies are still eligible for ABC purposes.
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