Free Letterbox Delivery - Regional Publications

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Free Letterbox Delivery [Print only]

Copies delivered on a regular and consistent basis to round level intended for onward letterbox distribution to known addresses.

Principles

1. Prior notification of distribution details and any changes to ABC

2. Distribution follows a regular and consistent pattern

3. Copies are delivered to round level intended for onward distribution as single copies through letterboxes in the round

4. There will be effective management controls over distribution

Requirements 

1. Prior notification of distribution details and any changes to ABC

1. You must inform ABC before the distribution of the first issue for which you intend to claim free letterbox, including the following information:

   1. A list of all distribution rounds, with the number and details of addresses intended for free letterbox distribution

   2. Details of how the distribution will take place, including the type of distributors employed and the basis, i.e individual distributors; third party teams etc

   3. The controls over the distribution, including processes for complaints of non-delivery.

2. You must, on an on-going basis, be able to provide ABC, on request, details of current and historical distribution rounds and the distributors used.

2. Distribution follows a regular and consistent pattern  

1. The quantity of copies distributed and rounds distributed to must be broadly the same for all issues.  Note:

   • Only for publications published more frequently than weekly (e.g. daily) the distribution may be varied without limit between each issue. For example: Mondays 10,000 copies, Tuesdays no copies, Wednesdays 5,000 copies etc.

   • It is accepted that there will be some change in the distribution between issues.  However you cannot include in your free letterbox claim any rounds where planned rotational or planned intermittent delivery has occurred during the audit period (note: rounds uncovered due to unavailability of distributors are not deemed to be intermittent). Note: Rotational or intermittent delivery can be claimed as Sample Free Distribution.

2. Only distribution in the UK or Republic of Ireland can be claimed.

3. You may deliver your publication using distributors, teams or a contract distribution company.

3. Copies are delivered to round level intended for onward distribution as single copies through letterboxes in the round

1. Distribution should be made to the known addresses within a round.

2. Copies can be distributed to multiple-residental units (e.g. A single building converted into two or more flats) providing:
   
   i) Distribution is made to an area where access is restricted to residents of the multiple residential unit.  For example through a communal or secure letterbox as opposed to distribution to a lobby area accessible by the general public.
   
   ii) The number of copies claimed for a multiple residential unit is the number of copies distributed into that unit limited to the number of households, up to a maximum of 10.
   
   

3. ABC must have the right to contact addresses and distributors for verification purposes.

4. You must be able to provide evidence of the number of copies of the publication that has been received by the distributor, team leader or contract distributor who is engaged to deliver them to the addressees in the round(s). If the receipt is for more than one round, then it must be clear that this is the case, and each round identified.

5. You may use different types of distributors, as follows:

   Distributors: A distributor is a named individual who is allocated a round or rounds and delivers the publication in person to the addresses.

   You must keep:

   1. 1. A  list of the names and addresses of all distributors involved in the delivery of each issue, that identifies for each distributor:

         • The rounds they have covered

         • The number of copies they have delivered

         • The amount(s) they have been paid

         • The method of payment

      2. Financial records that support individual and total payments to each distributor (for example purchase ledger records and bank statements). In addition:

      • • Cash payments must be evidenced by a signature of the person handing the payment over (e.g. Driver, Team Leader)

        • Payments for leaflet deliveries and other expenses must be shown separately

   Teams: A team is two or more people who deliver the publication under the control of a Team Leader. Teams are used to deliver to a group of rounds which have not been allocated an identifiable distributor. 

   You must:

   1. 1. Verify the identity of Team Leaders

      2. Identify for each issue those rounds delivered by teams 

      3. For each issue:

         • Keep a list of the names and addresses of team leaders and team members

         • The rounds they have covered

         • The total papers delivered

         • The amount(s) they have been paid

      4. Have financial records (for example purchase ledger records, invoices and bank statements) that show you have paid for the team deliveries.

   Contract distributors: A contract distributor is an external company that you have contracted to deliver the publication. If you use a contract distribution company that is a subsidiary or associated company of your company (or your publishing group) then this section does not apply, instead you should refer to either distributor or teams whichever is appropriate.

   You must:

   1. 1. Retain responsibility to report the distribution figures and make sure the required records to support the distribution claim are available (whether at your offices or those of your contractor).

      2. Be able to provide invoices from the contract distributor and evidence that these have been paid.

6. You cannot claim distribution of back issues.

4. There will be effective management controls over distribution

1. If your systems and controls indicate any apparent failure in the scheduled distribution then the copies affected must not be claimed.

2. You must keep up to date records for each and every round. The records must detail the addresses that you plan to deliver to. You should ensure that historical records are available for each issue in the audit period. The records must:

   1. Clearly define the boundaries of the distribution area

   2. Identify which postcode sectors are covered

   3. Identify any areas within the boundaries that are not delivered to

   4. Detail the streets and roads covered by individual distribution rounds and any exceptions.

   5. Contain instructions to identify any households within the round that are not to be delivered to

   6. Allow the distribution rounds to be referenced to the appropriate payment records

   7. Be updated within a month of any change to the distribution area, postcodes covered or distribution rounds. The dates and detail of any changes to rounds must be recorded.

3. It is good practice to maintain a record of complaints of distribution failings. These can arise from a variety of sources ranging from addressees not receiving a publication to discrepancies identified from your own processes. Your records should be kept in a uniform way, noting the complainant the nature of the complaint, and the actions taken, including any amendments to your claim.

4. If you use a contract distributor we will require them to have effective distribution controls and reporting in place. Scrutiny of these should be available to your auditor and ABC. 

Guidance Available

Reporting

Mandatory

Average Free Letterbox per issue for the period for the period [reported as Free Copies] analysed by:

1. Print

Optional

1. A verifiable overview description of the Free Copies claim

2. The average Free Copies claim analysed into:

   1. Regular:

      1. Free Pick Up Copies (print only), optionally broken out by:

         • Gross distribution

         • Net Distribution

      2. Free Letterbox (print only)

      3. Free requested

   2. Sample:

      1. Free Pick Up Copies (print only), optionally broken out by:

         • Gross distribution

         • Net Distribution

      2. Free Letterbox (print only)

      3. Free requested

3. Analysis of Free Letterbox for the last issue in the period (ignoring excluded issues) by postcode sector

   1. Daily publications may report this for each issue in the last week of the period.

Guidance

G4. There will be effective management controls over distribution

1. The publisher is responsible for ensuring that the copies they claim have been delivered and undelivered copies are accounted for. This requires a publisher to have appropriate management controls and processes in place to ensure that this is happening.  

   1. 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, live monitoring of electronic distribution records etc.

   2. 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.

   3. 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.