General Principles and Record Keeping - Website

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General Principles and Record Keeping

This section sets out some key requirements relating to the overall reporting and auditing of your ABC claim.

Principles

1. Evidence to support the claim must be retained and available for a minimum period

2. Transactions related to the claim must be bona fide ‘arms length’ arrangements

Requirements 

1. Evidence to support the claim must be retained and available for a minimum period

1. You must retain and be able to provide all records supporting the claim, including an analysis by each Website/App reported.

2. You must retain the records supporting the claim for a period of 6 months following certification of the claim or until the audit of the certificate for the subsequent Reporting Period has been completed if sooner.

2. Transactions related to the claim must be bona fide ‘arms length’ arrangement

1. Transactions or arrangements (such as sales or distribution services) with your own organisation or Related Parties will initially be deemed as not bona fide ‘arms-length’ for ABC purposes, meaning they cannot be included in your claim. However, they can be included if you are able to demonstrate to the satisfaction of your auditor that these comply with the Reporting Standards and are bona fide ‘arm’s length’ arrangements.

2. Related Parties for ABC purposes will include where:

   1. One party has direct or indirect control of the other party; or

   2. The parties are subject to common control from the same source; or

   3. One party has influence over the financial & operating policies of the other party to an extent that the other party might be inhibited from pursuing at all times its own separate interests; or

   4. The parties, in entering a transaction, are subject to influence from the same source to such an extent that one of the parties to the transaction has subordinated its own separate interests.

   5. Transactions between contract publishers and their clients are deemed not to be arms length in relation to a specific publication produced for that client.

      This means the following are considered Related Parties for ABC purposes:

      • The publisher, its subsidiary, parent and fellow undertakings (and Directors of these)

      • Associates and Joint Ventures (and their investors)

Guidance 

No additional guidance.