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Many of the new Verified Bulk Distribution reporting categories require the distribution to be conducted ‘Under Arrangement’ with a third-party. E.g. Education Distribution requires a title to be distributed ‘under arrangement by or with the Media Member for distribution at a learning institution’.

Under arrangement implies that there are at least 2 parties involved in the arrangement. As such, the evidence you provide your auditor should include communication between yourself and the third-party including an acknowledgement or acceptance from the third-party to proceed with the distribution.

A quick email to a third-party advising of your plans to distribute to their premises alone will not suffice.

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