Free Pick Up Copies - Regional Publications
Free Pick Up Copies [Print only]
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 inform ABC before the distribution of the first issue for which you intend to claim pick up copies, including the following information.
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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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You must, on an on-going basis, be able to provide ABC, on request, details of current and historical distribution points, quantities amd distribution dates.
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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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 any optional overview description or analysis reported.
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ABC must have the right to visit or contact distribution points for verification purposes.
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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 a daily Distribution Cycle
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 10% of total average free pick up for Mondays for previous ABC reporting period.
5,000 for Wednesdays must be within 10% of total average free pick up for Wednesdays on previous ABC reporting period.
20,000 for Fridays must be within 10% of total average free pick up for Fridays on previous ABC reporting period.
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For example: Weekly title with a 2 week Distribution Cycle
Week 1 Week 2 Week 3 Week 4 Circulation Qty 10,000 9,000 10,000 8,600 Dist’ points City Centre Suburbs City Centre Suburbs In this case, with the exception of ad hoc or seasonal variations, if the total average free pick up distribution for previous certificate is, say, 9,500 then each issue (for all Distribution Cycles) must be within 10% of this – i.e. between 8,550 and 10,450.
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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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In the case of copies that are not distributed solus but are packaged with other free or paid publications, inserted in other publications or in goody bags you must be able to demonstrate the copies are distributed using that mechanic. This may include providing evidence of insertion, packaging, sales etc. We recommend you contact us for advice on evidence required.
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If free copies are distributed via a retail multipack with a paid publication the claim should be restricted to the paid publication’s net sale. If at the time you submit your circulation claim unsold copies could still be returned or reported you must make an estimate of the final net sale. You must adjust your claim in the following period to reflect any difference between the estimated net sale and the actual net sale.
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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 non-daily publications, all copies must be delivered and made available within 24 hours of the majority of the rest of the distribution (with the exception of top-up copies – see below).
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You can make ‘top- up’ supplies of an issue after the initial supply at a distribution point, as long as:
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They are delivered before the distribution of the subsequent issue.
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For non-daily publications:
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The initial supply to a distribution point is made within 24 hours of the majority of the rest of the distribution
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Any top-up supplies to a particular distribution point beyond the initial supply are not individually greater than the initial supply.
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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 publications (except copies distributed airside, on trains or ships): must be reported on a net basis (i.e. those made available less copies not picked up by consumers).
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Non-daily publications, and all publications distributed airside, on trains or ships, must be reported on a gross (i.e. supply) basis.
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In the case of copies distributed to third party distributors for onward distribution to airlines (for airplanes and/or lounges) and trains or ships:
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Copies may be claimed as gross distribution providing ABC is given full and free access to the distributor’s contractual arrangements, invoices and documentation to enable verification of the onward supply.
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The gross distribution claim must be restricted to the quantity verified as onwardly distributed to the airlines, trains or ships and not the quantity supplied to the distributor.
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As an option you can report copies of non-daily publications distributed in a public place (either by hand merchandiser or via distribution bins) on a net basis as long as:
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There are 1 or more distinct Distribution Cycles, each cycle being completed within 24 hours.
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For each distinct Distribution Cycle you have third party evidence of the net distribution (i.e. those made available and actually collected/handed out).
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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
Mandatory
Average Free Pick Up per issue for the period [reported as Free Copies] analysed by:
An analysis of total average Free Pick Up copies that are distributed packaged with other products (as opposed to solus). This will include quantity and description.
For example:
Packaged copies:
500 copies distributed at hotels with XYZ magazine.
1,213 copies packaged with PQR magazine in a retail multipack
Optional
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A verifiable overview description of the Free Pick Up claim
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The average Free Copies claim analysed into:
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Regular:
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Free Pick Up (print only), optionally broken out by:
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Gross distribution
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Net Distribution
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Free Letterbox (print only)
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Free Requested
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Sample:
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Free Pick Up (print only), optionally broken out by:
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Gross distribution
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Net Distribution
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Free Letterbox (print only)
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Free requested
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Analysis of Free Pick Up for the last issue in the period (ignoring excluded issues) showing for each distribution point type (e.g. hotels, train stations):
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the number of distribution points; and
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the number of copies claimed
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Guidance
G1. Prior notification of distribution details to ABC
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The method of distribution statement should be as detailed as possible but must also be verifiable from evidence.
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The master list of all distribution points. We would expect this to include the following for each distribution point:
- Unique point ID (to enable clear identification when changes are made).
- Address, including postcode.
- Audience Type. For example airside/international rail, hotel – as analysed on the Certificate.
- Whether there is a responsible individual based at the point, a deliverer places copies on display, or it is a hand distribution point.
- Point description. For example: type of bin, location at address.
- 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.
- Name of responsible person:
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- Name of recipient for distribution points where individual based at point confirms delivery.
- Name of deliverer (in-house or name of delivery company) where deliverer confirms delivery.
- Telephone number of responsible individual.
- Normal day/date of delivery.
- Approximate time of delivery.
- Method of delivery. For example: in house, name of 3rd party distribution company.
- Normal supply quantity.
- Normal day/date of collection of returned/damaged copies (net copies only).
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Additional details as above for all regular top-up supplies.
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The master list of all distribution points must be supplied to ABC at the time the distribution point and process is submitted to ABC for approval prior to certification. All changes to the above details for existing distribution points, any removal of distribution points and all additions to the distribution points should be notified to ABC as and when they occur.
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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:
- Name/identification of distribution point
- Type of distribution point (e.g. hotel), manned or unmanned
- Gross supply
- For copies claimed on a net basis:Returned/damaged copies
- Net distribution if applicable
- 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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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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