C 3.1 Employee, Correspondent and Agent Copies

A newspaper may include as a sub-category of “Verified Circulation” copies served (or made readily available for pick up in the normal work environment by) to employees, retired employees, correspondents and agents under the following parameters:

(a) To be classified as an employee, individuals must be, or have been, on the regular payroll during the reporting period of either the newspaper or a wholly-owned subsidiary of the newspaper that is actively engaged in the production or distribution of the newspaper. Employees of subsidiary organizations, such as radio and television stations, job printing plants and so forth, that are not actively engaged in the production or distribution of the newspaper, are not eligible.

(b) To be classified as a correspondent, individuals must contribute at least one article per month that is printed in the newspaper.

(c) To be classified as an agent, individuals must be currently involved in delivering the newspaper to subscribers.

An individual classified as an employee, correspondent or agent for more than one newspaper may be included in the “Average Verified Circulation” of only one newspaper.

(d) Adequate records must be maintained by the newspaper (employee payrolls, records of correspondent compensation, agent billings) to support its claims.

C 3.2 Educational Programs

(a) A newspaper may include as a sub-category of “Verified Circulation” the classification "Educational Programs" and if shown shall include only copies ordered for delivery to schools. Only those copies that have supporting documentation confirming usage (i.e., affidavits from schools, verification of delivery and receipt, etc.) available for auditor review may be reported as verified distribution.

(b) Distribution of copies outside of structured classroom settings may also qualify as verified circulation, and reported as Educational Copies provided the following conditions are met:

(1) The copies are served in conjunction with a formal program designed to encourage literacy and continuing education of the participating student by assisting the student family to improve their life and job skills.

(2) The program in question establishes minimum participation standards for the student family, and the student family achieves those minimum standards.

(3) Auditable records demonstrating the student's enrollment in school, the program in question, completion of minimum participation standards are maintained.

(4) Only one copy per participating student family household may be claimed.

(5) Schools and classrooms offering home delivered copies must also participate in NIE programs requiring classroom usage of the newspaper.

C 3.3 Other Verified Distribution

(a) Home Delivery - Requested

Copies delivered to households based on a request from the household for delivery may be reported as: Verified Home Delivery – Requested under the following conditions:

1. Distribution occurs for at least 12 weeks
2. A member of the recipient household specifically requested delivery of the frequency being delivered, and requests are renewed at least annually if delivery duration equals or exceeds one year)
3. Each issue delivered includes a clear and conspicuous notice that provides a phone number and online address for the consumer to use to opt-out of future deliveries.
4. Publishers are required to contact each receiving household on an annual basis to confirm desire for ongoing delivery and provide options to opt-out if desired. Contact may be via mail, email, phone call or automated phone call. Receiving households should be given easy opt-out mechanisms such as push-button response during an automated call or replying to an email.
5. Records are available for the auditor to confirm the request.

ABC Audit Reports shall include an analysis of all verified - requested distribution by age of request as follows: Less than 1 year; 1-2 years; 2-3 years; and 3+ years. The analysis shall be based on Paragraph 3 dates and should be inclusive of all requested distribution for all editions of the newspaper. The analysis shall be repeated in ensuing Publisher's Statements.

(b) Home Delivery – Targeted

(Publishers planning to serve Home Delivery - Targeted copies are required to notify ABC at least 120 days in advance of the first day of delivery.)

Copies delivered to households may be reported as Verified Home Delivery – Targeted under the following conditions:

1. Households targeted for delivery are notified on the first day of delivery
2. Notification includes anticipated dates of delivery
3. Notification must include options for household members to contact the publisher to ‘opt-out’ of delivery
4. Publishers must maintain route lists of all targeted-delivery programs and, if requested by the auditor, provide copies to ABC at least two weeks prior to the commencement of a program. Failure to provide requested audit documents will result in the exclusion of the copies from Verified Circulation claims.

(c) Other Verified Distribution

In addition to Employee (print or digital service) and Educational Program (print or digital service) copies as noted in Rules C 3.1 and C 3.2, distribution to the following venues may be included in “Verified Circulation” provided each location makes a specific request for delivery. The request should include an acknowledgement by the requestor that the copies are intended for use by patrons.

• Hospitals & Nursing homes
• Restaurants
• Doctor / Dentist offices
• Other ‘public place’ locations (e.g. barber shops, salons, etc.)
• Airlines

In addition, copies to be distributed through retail outlets will be eligible for inclusion in Verified Circulation provided the retailer makes a specific request for the number of copies and the copy counts represent reoccurring distribution to patrons.

Also, copies distributed through publisher maintained venues (honor boxes, etc.) are eligible for inclusion in Verified Circulation provided such distribution is consistent in volume and location.

No other single copy distribution is eligible to be reported as Verified Circulation.

C 3.4 Business/Traveler Copies

(a) Business Copies
All copies or subscriptions purchased in quantities of 2 or more by corporations, institutions or individuals for employees, subsidiary companies or branches may be included in paid circulation as an element of “Paid Business / Traveler Circulation, Group (subscriptions by Businesses for Designated Employees)" provided either:

(1) The newspaper has records indicating names or titles of the employees, or

(2) Subscriber records are available for Bureau verification indicating the names or titles of those receiving the newspaper.

(b) Traveler (Hotel) Copies
All copies purchased by hotel guests as described in this rule and / or purchased by hotels for distribution to guest rooms may be included in paid circulation as an element of “Paid Business / Traveler Circulation, Hotel Distribution.” Copies allocated to this category shall be further classified as follows:

“Guest Refund based” – copies distributed to guest rooms wherein the guest is notified upon check–in that a specified amount is included in the price of the room for the newspaper and that amount will be refunded should the guest elect not to receive the newspaper.

“Purchased by hotel” – copies intended for distribution to guests.

C 3.5 Gift Subscriptions

(a) A Gift Subscription shall be considered one, which is given as a normal expression of friendship and which does not promote the business or professional interests of the donor.

(b) To qualify, Gift Subscriptions must be paid for in accordance with C 1.1.

(c) Subscriptions which are given to promote the professional or business interests of the donor shall be judged by the rule governing Verified Circulation.

(d) In no case where an order (or orders) from a single donor covers more than fifty subscriptions shall the subscriptions be regarded as Gift Subscriptions but shall instead be classified as term subscriptions in third-party, provided they conform to the rules governing Verified Circulation.

C 3.6 Gift Subscriptions Not Recognized as Paid Circulation

(a) Gift Subscriptions paid for by subscription salespersons or others who are compensated by merchandise or other rewards in lieu of cash commission.

(b) Gift Subscriptions which have been paid for by someone who has been offered a premium and the amount received is less than the full value of the premium plus one cent.