BUSINESS MANUAL

ASSETS

Cost Justifications (Revised 1-25-12)

Any individual may recommend an asset purchase by submitting a Cost Justification to his/her

team leader.

Assets are items that cost $100 or more and have an expected useful life of one year or more. In

addition to equipment, furnishings and motor vehicles, intangible assets such as a market survey

may be included. All Assets are owned by the company, rented to each department or office

location, and listed on an asset inventory list maintained by corporate services. The

office/department asset rental charge is a monthly 2.5% of the total cost of the asset. For

example: The rental charge for a $1,000 computer is $25/month. The asset rental charge

continues for every asset until disposal of the asset has been approved.

1. Cost justifications: Assets may be acquired only after the INI Cost Justification review

has been completed and approved by inicorporate@newszap.com. The cost justification form

can be found under Company Forms in http://initoolbox.com and must be filled out completely.

All costs to make the asset operational, including other equipment, software, shipping,

installation, and training must be included in the cost justification. The contract, purchase

agreement, proposal or any supporting documentation should also be submitted with the cost

justification. For computer or software purchases, the requestor must also include the

specifications that were provided by techteam@newszap.com. Vehicles are handled the same as

any other asset.

Cost justifications should be compelling with significant savings or benefits to the company.

Corporate services will evaluate all cost justifications to make sure the investments are sensible

for the company overall and not just trade-off paper savings for a division.

Approval by the board of directors is required for cost justifications over $50,000.

2. Submitting a cost justification:

a. For all computer or software purchases, use the COMPUTER QUOTE REQUEST

FORM below. This should first be sent to techteam@newszap.com and copied to your

appropriate divisional or group team leader. The tech team specialists will recommend the

computer/software that is best suited to meet your needs, based on INI’s standardized technology

platform and the type of work to be done with this equipment. Once you receive the quote

information back from techteam@newszap.com you should then resubmit it along with the full

cost justification, using the cost justification form, to inicorporate@newszap.com and copied to

your appropriate team leader and group president, vice president or general manager.

b. For all other purchases, use the COST JUSTIFICATION FORM below. The cost

justification form, including all supporting documentation, should be sent

inicorporate@newszap.com and copied to your appropriate team leader and group president, vice

president or general manager.

3. Important details about the cost justification process:

a. Once a cost justification is submitted to inicorporate@newszap.com, the team and group

leaders copied on the cost justification will have two full business days to raise questions or

concerns they have about the purchase. If no questions or concerns are raised, it will be assumed

all parties approve the cost justification.

b. Final Approval & Purchase Order Numbers: Without waiting for objections,

inicorporate@newszap.com analyzes every cost justification.

Once two full business days have passed without objection, inicorporate@newszap.com will

send recommendations back to the requestor, ( cc: VP or GM, iniaccount@newszap.com &

inicorporate@newwzap.com ), along with the purchase order number and authorization to place

the order. (Sometimes we may opt to lease rather than buy the asset; lease versus purchase

decisions are made by inicorporate@newszap.com; all leasing negotiations and agreements are

handled directly by inicorporate@newszap.com.

c. Companywide purchases: In the case of major companywide purchases ($50,000 or more),

inicorporate@newszap.com may follow up directly with the vendor to negotiate contractual

terms and/or place the order. In such cases updates, including P.O. number and final terms, will

be shared with the requestor (cc: group president, VP or GM, iniaccount@newszap.com and

inicorporate@newszap.com). The Corporate Secretary (or another INI officer if secretary is

unavailable) will electronically sign all contracts.

d. Computer or Software purchases: Once the CJ is approved, techteam@newszap.com will

place the order. Tech Team member(s) will install all company approved software and anti-virus

protection, and see that your equipment is ready for use. All computers and software are licensed

to Independent Newsmedia Inc. USA.

e. Tracking purchases: iniaccount@newszap.com will create a file for the purchase order

number, follow through with payments per the contract, institute the asset rental or lease

payments, and update our assets lists. (Training and maintenance are expensed as routine

purchases and are not included in the asset rental charge.)

**********************

COMPUTER QUOTE REQUEST FORM (Revised 1-25-12)

TO: Techteam@newszap.com

TODAY'S DATE:

FROM:

LOCATION/DEPARTMENT:

COPIED TO: (Appropriate division or group team leader)

******************************************************************************

********

I. This is a request to acquire or replace a computer or software.

___Request computer for NEW use

___Replacement for worn out computer

___Request for laptop (Because of their higher cost, laptops are approved only if justified by the

computer's intended usage AND if the user has a proven history of good productivity.)

___Request for software upgrade or NEW software purchase

Briefly describe the tasks this equipment will handle and include a description of any features or

uses necessary to meet job requirements:

Once techteam@newszap.com has returned the quote and specifications, forward the quote along

with the cost justification form to the appropriate group president, vice president or general

manager.

**********************

Cost Justification form:

Assets: Cost Justification: (Revised 1-25-12)

TO:

COPIED TO: (Appropriate division or group team leader)

TODAY'S DATE:

FROM:

LOCATION/DEPARTMENT:

This is a request to purchase the new asset described from an outside vendor or the company

surplus asset lists.

Brief description of the asset:

Vendor name:

Cost of new asset, including all additional equipment, installation, training, maintenance and

shipping, and BEFORE trade-in allowance:

Monthly asset rental charged by Independent (costX.025):

With existing asset:

With new asset:

Difference in Monthly Asset Rental Cost would increase/decrease by:

OTHER FACTORS

Check those which apply. Explain below, if appropriate.

___This new asset is a replacement for a worn-out item.

___Complete repair/rebuilding of existing asset would cost $ and ____ is ___is not an

option for reasons below.

____If this is a replacement, check here and describe the asset being replaced (include INI asset

number, serial number, model etc.). Also indicate your recommendation for future use/disposal

of old asset (Remember, you will need to complete an Asset Disposal Form once new equipment

is installed):

Monthly regular payroll cost (list ONLY if it will change as a result of new asset)

With existing asset

With new asset

Monthly overtime payroll cost (list ONLY if it will change as a result of new asset)

With existing asset

With new asset

Monthly utilities cost (list ONLY if it will change as a result of new asset)

With existing asset

With new asset

Monthly maintenance cost, including maintenance agreement (list ONLY if it will change as a

result of new asset)

With existing asset

With new asset

Additional monthly rental charge to fully repair or rebuild existing asset - .025Xcost to

repair/rebuild (list ONLY if it is an option):

Monthly housing cost (list ONLY if new asset requires that we rent more or less space):

Monthly other costs (list ONLY if other costs will be incurred or saved by new asset):

TOTAL MONTHLY COSTS FROM ABOVE

With existing asset

With new asset

DIFFERENCE: MONTHLY COST WOULD INCREASE DECREASE BY: $

Explanations and Other Information:

Only corporate officers or their designees may sign contracts. Copies of the proposed purchase

agreement (including proposed payment terms and warranty information) must be attached for

approval and signature by corporate officers. If the vendor offers the option to lease instead of

purchase, a copy of the lease agreement should also be attached.

Inicorporate@newszap.com will email approval and follow up instructions to the individual who

submitted the Cost Justification within two business days (this 2-day ‘waiting period’ allows

time for senior managers to comment on the Cost Justification).

BACK TO TOP MAJOR BUILDING REPAIRS For Independent's property Although Corporate Services is the internal landlord for all real estate owned by

Independent, the local division is either assessed a rent increase or charged a one time

expense on their P&L'S for all major repairs and improvements. This includes normal

maintenance items such as painting, electrical repairs, replacing doors and repairing

condensing units and heaters etc. as well as major replacements or additions to the building

such as carpeting, a new roof or vinyl siding, new parking lots, permanent signs (usually

attached to the building), new condensing units or hot water heaters. This policy puts the

decision and responsibility at the local level where accountability will best serve the division

and company. All major repairs or improvements exceeding $100 are subject to the same cost justification

process and signatures as the acquisition of an asset. This should include as much

explanation as possible about the need for the repair. Corporate Services will notify the local

division when the cost justification has final approval.

For emergency repairs, email inicorporate@newszap.com immediately. If the improvement

is a major repair costing over $1000, at least three separate bids should be sought from

contractors or suppliers. If the total proposed expenditures exceed $25,000, the planned

improvement is reviewed by the board of directors. * Standard repairs will be expensed directly to the division as regular building maintenance.

If such a repair is large enough to distort the division's P&Ls, Corporate may take the

expense and charge the division 2.5% asset rental. * Accounting standards require major building repairs, such as a new roof, new condensing

units, etc., be capitalized for tax purposes. Such repairs will affect the division as an internal

rent increase by 2.5% of the expense -- similar to normal asset rental. * New additions to a building will be assessed separately, most often reflecting the current

charge for square footage for the new space. Contact iniaccount@newszap.com directly for advice about how accounting standards may

apply in any given situation. Since it is Independent's policy that a division pays all repairs and improvements, internal

rents should be a bit below competitive rates. It also is a company policy not to distort any

division's profitability by giving it a special deal on rent (or any other service.) Therefore,

once a year, a 5% internal rent increase is considered for any division paying less than 90%

of the average that the company pays outside landlords.

BACK TO TOP

CASH BOXES (revised February 2010)

Definition, Purpose & Set Up: A Cash Box is to be used ONLY for handling customer

cash transactions, typically for classified reader sales, cash subscription payments etc. It is

NOT to be used as a petty cash fund to pay for office supplies, or to reimburse employees

etc. A Cash Box for customer transactions must always be kept separate from a petty cash

box and should be maintained in a separate area. (Customer service specialists should

ALWAYS presume that payments will be made via credit or debit card and only accept cash

or check as a last resort). To set up a NEW box, fill out a request for the initial balance of the box on

a Reimbursement Request and email the form to iniaccount@newszap.com (cc: VP or GM).

The beginning balance of a cash box should be just enough money to adequately provide

customer change. (Creating a new cash box or increasing the balance requires the approval

of the president). Assumption of Responsibility: Any individual who handles a company Cash Box must

accept individual responsibility for the funds by completing and signing the INI Cash Box Assumption of Responsibility (found in the Company Forms section of

the initoolbox). Once signed, the form should be scanned and sent via email to iniaccount@newszap.com (cc: team leader and the appropriate vice president

or general manager). Whenever a permanent reassignment of the box occurs, the new person must file an Assumption of Responsibility

form, following this same process. The “signed” form is kept on file in

a network folder managed by iniaccount@newszap.com. . . Ideally, at least two people in each office should have Cash Box responsibilities (one as

primary and other as back up and to balance the box). Both must have an Assumption of

Responsibility form on file. The primary person typically controls access to the Cash Box for

every customer transaction and then prepares the Daily Cash Receipt reports at the end of

the day and reconciles the reports with the funds in the box. The back up person should

also reconcile the Cash Box balance and cash receipts each day and then prepare the

deposit slips and make the day’s deposits. These two individuals should be cross trained and

frequent reversal of their responsibilities is highly recommended.

When the primary individual responsible for a Cash Box is on vacation or otherwise

unavailable, the back up person should handle the box. If he/she is not available it is

possible to temporarily transfer responsibility for the fund or a portion of it to another

individual in exchange for a signed receipt (from the INI Cash Receipts Book which is used

to manage the box). The fund should be reconciled when the responsible individual returns.

Cash receipts: Every Cash Box must have its own Cash Receipts Book. A receipt must be

written for every customer cash transaction from the Cash Box. These receipts must bear a

description of the transaction, as well as the signature -- in ink -- of the employee handling

the transaction. . The receipts book must be composed of three-part forms, preferably in white, yellow and

pink copies, with receipts printed in numerical sequence. The original receipt is always given

to the customer, the second (usually yellow) copy must always be attached to the day's

Daily Cash Receipts/Cash Sales report and the third (usually pink) copy should be

maintained for department records. No receipt should ever be destroyed; there must

always be an accounting for voided or otherwise unused receipts. Customers may only be

given change for true cash transactions. (Customer payments by check must be for exact

amount due). Cash boxes are subject to unannounced audits at the discretion

of iniaccount@newszap.com.

BACK TO TOP

CREDIT & COLLECTIONS Objectives: A. To develop "brilliantly simple systems" companywide that streamline our procedures and

speed our collections cycle. B. To reduce our slow pay and bad debt experience. C. To avoid losing customers due to lax credit policies that allow them to get in over their

heads. D. To help us maintain long-lasting mutually beneficial relationships with our display

advertising clients, with a minimum of stress upon our clients, our credit managers, our

advertising consultants, sales leaders and senior leadership. 1. ESTABLISHING CREDIT.

a) Advertising consultants will submit an Account Information/Credit Application Form to

collect@newszap.com on behalf of any client desiring credit. It is vital that the form be

timely, complete and accurate. Think of this as scheduling an ad. The process calls for completeness of the) AIF up front.

Missing info will delay the processing of credit application. This means complete contact info

with name, phone number, fax number and email address if any. b) The ad consultant will be notified via email by collect@newszap.com of credit approval or

denial within one working day of receiving the credit application. Explanation: Many of our credit problems begin with incomplete or inaccurate Account

Information Forms. If these are correct from the start, a quick approval or denial of the

credit application will be possible, and many misunderstandings will be avoided. INTERNAL: Receipt of and Approval/Denial of credit apps to ad team (use email): (All credit applications will be reviewed and determined within a 24 hour period. It will be

the responsibility of collect@newszap.com to contact customers whose applications may be

incomplete or insufficient for processing.) MEMO TO BE USED:

Dear Sales Team,

The following credit applications were received and have been approved or denied credit as

noted below. Please review this list.

If you have questions kindly send them via email to collect@newszap.com.

Account Number/Name Date Received Approved Credit Limit Denied

____________________ [ ] $ [ ]

____________________ [ ] $ [ ]

____________________ [ ] $ [ ]

____________________ [ ] $ [ ]

For a summary of our credit and collections policies, please click here.

Thank you,

2. APPROVING CREDIT. The credit department will use a credit reference service to determine the applicant's

creditworthiness. If a customer's credit demonstrates a history of timely payments, it is

normally safe to extend credit. After outside credit information is reviewed,

collect@newszap.com will decide whether to extend credit and what the monthly credit limit

should be. These customers will be assigned an approved credit status within the Media Plus

billing system. When the ad consultant is notified that credit has been approved, he or she

may choose to inform the client by telephone, email or letter. Future increases to the credit

limit will be considered based on the client's payment history. Explanation: We want to use reputable third party credit collection services because they

are the industry standard, because they can provide better information faster and more

efficiently than we can do it ourselves, and because we want to be able to cite a third party

as the basis for our credit decisions. We want to eliminate the need for credit approval

memos or lists (that may quickly be outdated) by referring the local offices to the Media

Plus advertising system for always-current info. We want the ad consultant to be able to

deliver the good news to the client that credit has been approved. 3. DENYING CREDIT a) Credit will be denied to clients who previously had credit with us and lost it, unless

the group’s vice president or another corporate officer approves an exception based on

extenuating circumstances. (Also see #8, below.) b) Based on third party credit services, customers who do not have solid payment histories

will not be extended credit. These customers will be marked with a CWO credit status in the

billing system and will be required to prepay for any advertising. (Prepayment can be made

by cash, money order or cashier's check. Also by credit card if there is no history of credit

card reversals, or by check if there is no history of a check being returned for non-sufficient

funds.) The credit department will always seek win-win solutions when possible (i.e. special

terms). c) Credit is not extended --- and credit card payments are not accepted --- for: - * Going out-of-business sales -- no exceptions, even if client has done business with us for

many years. - * Political ads-- school board and local elections, as well as national and state. - * Seasonal businesses --Christmas tree sales, fruit and vegetable stands, possibly

restaurants which operate on a seasonal basis. - * Transient advertisers such as circuses or sales or auction being held in a local hotel. - * Financial lender ads other than recognized institutions that have established credit - * Palm readers, fortune tellers, etc. - * Businesses that only have a P.O. Box number - *High-risk businesses --- often special training studios, craft items, etc. Explanation: We will no longer accept credit card payment from these accounts. The reason

for the change is that such payments often result in charge-backs from the credit card

companies. These should be CWO clients with ads not scheduled until payment is received. d) If a credit application is turned down, a denial letter is emailed, mailed or faxed to the

customer. The customer is invited to reapply for credit if the situation with the outside

credit checking agency changes. The letter encourages the client to develop a business

relationship with us on a cash basis. The letter also mentions that if a business owner is

willing to sign a personal guarantee, we can check the owner's credit and consider issuing

credit to the owner.

4. MAINTAINING CREDIT. REVISED 5/05

ACT FAST consists of the following steps:

--Ask every delinquent account for a FIRM date by which payment will be received.

--Call EVERY delinquent account at least once a week until payment is received.

--Take payment via credit card, check by phone or other methods of immediate payment

whenever possible; DURING EVERY CONTACT WITH AN ACCOUNT ALWAYS ASK if you can

process payment on a credit card or check by phone so as to preserve their credit standing

and avoid further action.

--FAST response to every dispute or error so disputes do not become the 'reason' for non-payment.

Explanation: Fast contact and timely follow-up are the keys to collections. In collections, the

"squeaky wheel" gets paid first. It is important that the client learns that the newspaper is

100% committed to resolving problems and following up on promises. This can be done with

firmness, but also with unfailing courtesy. Internally, we might want to refer to these all-

important calls as our own "dialing for dollars" program, but we should also feel a keen

sense of service to the client by helping to maintain the client's good credit rating. b) If the collections call reveals a billing or posting error, collect@newszap.com will

email billteam@newszap.com . All such errors must be corrected by the billing team within

two days, with the resolution being confirmed by email to collect@newszap.com. The

collect@newszap.com team will always apologize to the client and let the client know that

the problem has now been corrected. c) If the collections calls reveal some dispute other than a billing or posting error,

collect@newszap.com will email the ad consultant immediately to describe the dispute, and

cc the appropriate group ad team. All such disputes must be resolved with the client by the

ad team within 2 business days of being informed about the dispute, with the resolution

being confirmed by email to collect@newszap.com. (Ad consultants and their team leaders must face up to and resolve all disputes as soon as

possible. Many of this company's worst collection problems have occurred because the ad

consultant didn't want to face up to disputes. The longer a dispute is allowed to remain

unresolved, the bigger the problem becomes and the more likely it becomes that the

company will lose a client and possibly experiences a bad debt Write-off. It is important the

communication is complete with all info initially in order to the ad or ad office coordinator to

expeditiously resolve the info.) d) Our credit managers are empowered to cut off credit as soon as they lose confidence in

the client's intention to pay, such as a client being unresponsive to phone calls or letters;

missing a promise-to-pay date; not following through on a commitment; or paying with a

check that is returned for non-sufficient funds. (In the past we've often waited until a client is at 60 days (i.e. - 30 days overdue) before

withdrawing credit. This makes no sense, and allows some clients to run up balances that

make it difficult for them to catch up and tempting for them to simply walk away from the

debt. Why wait until 60 days if our credit manager feels we're at risk after making the 30-

day call?

There is no good reason for our ad consultants, ad leaders or corporate officers to be

involved in these decisions. Their stock response to client inquiries could be something like

this: "I'm not in the loop regarding payments. Let's allow your people to work this out with

our credit manager". Our credit managers are professionals, and little benefit can occur

when sales people put themselves in the middle of payment issues. The power to cut off credit is a tremendous tool that should help collect@newszap.com in

their collection efforts. The group’s vice president or corporate officer can overrule such

decisions, but should do so only if convinced that the decision was ill-advised after hearing

the credit manager's reasons.) e) When we've cut off credit to a delinquent account, we'll still accept CWO advertising ---

but only at the OPEN rate (not contract rates), and only if the client also pays 10% of the

outstanding previous balances. (Strict enforcement of this policy improves our chances of collecting the overdue balances

and restoring the client's credit.) f) There may be rare cases when the credit manager will allow a longer payment cycle for

certain accounts, such as certain government agencies that traditionally pay slowly. This

should be done only when we are confident that payment will be received. The group ad

teams will receive a jeopardy of suspension listing via email from collect@newszap.com five

(5) days after the close of the month. This gives the ad team a heads up of which accounts

whose ad will not be allowed to run on credit due to their outstanding balance. 5. THIRD PARTY COLLECTIONS. As soon as the credit manager feels reasonable internal collection efforts have been

exhausted (i.e. calls, letters, assistance by local team) the delinquent account should be

forwarded to third party collections or taken to Small Claims Court. 6. BAD CHECKS. We generally accept checks from clients unless a previous check has been returned for non-

sufficient funds. Some customers have a history of presenting non-sufficient funds checks

(bad checks). Credit should be denied these customers and advertising should be accepted

only on a Cash With Order basis. Payment must be made by cash, money order or cashier's

check. 7. CREDIT CARDS. Except as noted in 3c above, we generally accept credit card payments from clients unless

we've had a previous bad credit card experience with the client. Once we've had a bad

credit card experience with a client, we insist on cash, money order, or cashier's check. 8. BAD DEBTS. Even if an account has been "written off" for accounting purposes, the agency handling the

collection of bad debt accounts continues to try and collect old balances; and, "written off"

clients are still NOT eligible for new credit. (Also see 3a above.) We will always be willing to

pursue opportunities when circumstances change and we see an opportunity to forge a new

relationship that includes recovery of bad debts that were written off earlier. Questions or

issues concerning payment on amounts written off should be referred to

collect@newszap.com. 9. BANKRUPTCY.

Some accounts file for bankruptcy while still owing Independent a balance on their account.

Such accounts should be addressed on a case-by- case basis if they request future credit. A

suggested approach is to require the advertiser to prepay for all advertising by money order

or certified check. 10. EMPLOYEE ADVERTISING. Employees sometimes place advertising in our publications. Just as with any other business

client that hasn't established credit, they should prepay for any such ads. (We shouldn't discriminate against employees who have businesses and are able to

establish credit just like any other business. However, we shouldn't grant credit just

because they are an employee, and we could actually be accused of discrimination if we

were to do so. ) “Employee ads are rated at a 50% discount with the exception of ads placed for a business

owned or operated by the employee.” 11. FINANCE CHARGES. We are not a finance company; we pay interest to our banks for the money we borrow. We

already "carry" all of our credit customers for 30 days interest-free. Beyond 30 days, we

must impose finance charges to recover the cost of carrying the overdue debt. These

finance charges also provide a good incentive for our clients to stay current with us.

Sometimes our credit managers can use adjustments to the finance charges as a

negotiating tool; however they should use that tool only when they feel the client is not

trying to take unfair advantage. 12. APPLICATION. These policies apply to all advertising sold on credit. There may be occasional temporary

exceptions for marketing reasons, such as the introduction of a new category of advertising.

Any such exceptions must be approved by the group’s vice president or another corporate

officer PRINTING PLANTS POLICIES Printing customers are required to complete an Account Information Form. We should

attempt to arrange for payment with the job whenever possible. Printing customers can

apply for credit, and it may be granted, if it is necessary to get the job and if our chances

for payment appear good. Credit may be extended only with appropriate written approval.

Printing customers are billed upon completion of the job and should only be extended a

maximum 10 days of credit from the date of the invoice or until the next printing cycle

whichever is shorter. At the request of the printing company’s general manager or an

appropriate corporate officer, a request for 30 day terms may be granted contingent upon a

good credit report. New printing customers must pay prior to the printing of the job unless credit is extended. If a customer seeks credit, follow the Establishing Credit suggestions above. The account

information form must be completed and signed. It must include at least three trade

references and a bank reference. If a printing customer's account becomes delinquent, the customer is required to prepay for

any job prior to the printing process, plus AT LEAST 10% of the past due balance.

If a printing customer presents us with a bad check, the customer is required to replace the

bad check with a cashier's check prior to the next printing date. If the account has a history

of bad checks, the customer will be denied credit and required to prepay for all jobs by

money order or cashier's check. See Bad Check section. CLASSIFIED TRANSIENT CREDIT POLICIES Online ads are absolutely free for all three groups:

400 words

4 photos 4 weeks on newszap

Print ads follow the package rates set by each group.

COMMERCIAL ADS: All classified advertising placed by commercial establishments must be prepaid. In order to

receive credit, an Account Information Form must be completed and emailed to

collect@newszap.com for approval. Accounts that have approved credit must follow the

policies and procedures outlined in the Credit Policies & Procedures relating to display

advertising. The guidelines in determining whether an ad is to be considered a commercial

ad are: 1. Does the customer obtain a major portion of their income from this venture. 2. Does this

ad pertain to an enterprise that requires a major investment of time and money by the

person placing the ad or other interested parties? 3. Is profitability the desired goal of the

operation? 4. Is this a business that is required to be licensed by any government agency? If the answer to any one or more of these questions is "yes," the customer may be a

candidate for credit privileges. PUBLIC NOTICE ADS: The following Public Notice ads must be prepaid: * Liquor License * Name Change * Permit to Carry a Deadly Weapon * Not Responsible * Custody Petition CONTINGENCY PUBLIC NOTICE ADS: Certain legal ads placed in the paper by government agencies are paid on a contingency

basis--e.g., Estate Sales and Sheriff's Sales. Many times, Independent does not receive

payment for these ads until the billed agency is paid by another party. Occasionally, there is

a substantial time period before we receive payment for these ads. Any balances pertaining

to these ads will be retained in the Accounts Receivable for a period of one year and then

may be written-off as a bad debt. Any monies received after the account balance is written

off will be credited to "Recovery of Bad Debt". CIRCULATION POLICIES

Any store or dealer can apply for credit privileges with Independent by completing and

signing an Account Information/Credit Application Form. The completed AIF must be

emailed to collect@newszap.com. Stores may only receive newspapers for resale on a 7

day paid in advance basis until credit approval is received in writing from

collect@newszap.com. If a customer seeks credit, follow the Applying for Credit

suggestions above. If an account becomes delinquent, the customer is required to pay 7 days in advance plus

AT LEAST 10% of the past due balance. If a customer presents us with a bad check, they are required to replace the bad check with

a cashier's check. If the account has a history of bad checks, the customer will be denied

credit and required to pay 7 30 days in advance by money order or cashier's check. See

Bad Check section. CREDIT LETTERS Credit Denial Letter

Date

Insert Customer Name

Street Address

City/State/Zip

Dear Insert Customer Name:

Thank you for submitting a credit application to Independent Newsmedia Inc. USA

After reviewing the information obtained from a national credit reporting agency, we are

unable to extend credit at this time, but will be very happy to assist you with prepayment

terms (credit card, check, money order, other). If you'd like to sign a personal guarantee

for your business' advertising, we will gladly review your personal credit history and

consider issuing credit to you as the individual responsible for payment of the advertising bills.

When you are ready to schedule your advertising please contact your sales representative who will be able to assist you with these arrangements.

Once you advertise with us and establish a payment history with Independent, we will be

better able to reevaluate your credit application. We invite you to reapply if the situation

with the consumer credit checking agency changes. If you would like to discuss your

application further, please feel free to contact INI by email at collect@newszap.com. Your

email will be treated with the utmost confidentiality. If you prefer to speak with someone

please call 800-426-4192. INI relies upon credit information supplied by Equifax, a national

credit monitoring and rating service. If you believe that Equifax's record of your credit

history is incorrect we encourage you to contact their customer service department at:

Equifax Inc

P.O. Box 740249

Atlanta, GA 30374-0249

sbfe@equifax.com

1-800-727-8495

Report confirmation number: _______________________

As you will see on the reverse side of this letter, you can ask Equifax to provide you with a

copy of your credit report. This will allow you to dispute any inaccuracies and ask Equifax to

make corrections. You’ll surely want to do this in any case, since it may affect your credit

status with other vendors as well. Please be assured that we will gladly reconsider your credit application upon your request.

We already view you as a valued client, and we hope you will advertise in our products.

We're sure you'll be delighted with the results.

Professionally,

Corporate Credit Director

***

FLIP SIDE OF LETTER

Fair Credit Reporting

If you've ever applied for a charge account, a personal loan, insurance, or a job, someone

has a file on you. This file — known as a consumer report — contains information on where

you work and live, how you pay your bills, and whether you've been sued, arrested, or filed

for bankruptcy.

Companies that gather and sell this information are called credit reporting agencies, or

CRA's. The most common type of CRA is the credit bureau. The information CRA's sell about

you to creditors, employers, insurers, and other businesses are called a consumer report.

The Fair Credit Reporting Act, which is enforced by the Federal Trade Commission, gives you

specific rights in dealing with CRA's. It protects you by requiring credit bureaus to furnish

accurate and complete information to businesses when they evaluate your applications for

credit, insurance, or a job.

Here are some common questions about consumer reports and CRA's — and the answers.

How do I find the CRA that has my report?- Contact the CRA's listed in the Yellow

Pages under "credit" or "credit rating and reporting." Since more than one CRA may have a

file on you, call each until you locate the agencies maintaining your file. If your application

was denied because of information supplied by a CRA, the company you applied to must

give you the agency's name and address.

Do I have the right to know what's in my report? - Yes, if you ask for it. The CRA must

tell you everything in the report, and in most cases, the sources of the information.

Although the CRA is not required to give you a copy of the report, many do. You also have

the right to know who received your report in the past six months. If your inquiry concerns

a job application, you can get the names of those who received your report during the past

two years. Medical data is exempt from this rule, but your doctor may be able to get it for

you.

Is there a charge for my report? - Not if your application was denied because of

information supplied by the CRA, and not if you request your report within 30 days of

receiving the denial notice. If these requirements are not met, the CRA may charge a

reasonable fee.

What can I do about inaccurate or incomplete information? - Contact the CRA.

They're required to reinvestigate the items in question. If the new investigation reveals an

error, you may ask that a corrected report be sent to anyone who received your report in

the past six months. Job applicants can have corrected reports sent to anyone who received

a copy during the past two years.

What can I do if the CRA won’t modify my report? - The reinvestigation may not

resolve your dispute with the CRA. If so, have the CRA include your version or a summary

statement of the dispute in your file and in future reports. At your request, the CRA also will

provide your version to anyone who recently received a copy of the old report. There's no

charge for this service if you request it within 30 days after you receive your denial notice.

After that, there may be a reasonable charge.

Do I have to get the information in person? - No, you can ask that the information be

provided to you over the phone or by mail. However, to verify your identity, the CRA can

ask you to submit your request in writing. If you want to visit the CRA, you’ll need to make

an appointment.

Are reports prepared on insurance and job applicants different? - If a report is

prepared in response to an insurance or job application, it may be an investigative

consumer report. These are much more detailed than regular consumer reports. They often

involve interviews with acquaintances about your lifestyle, character, and reputation. Unlike

regular consumer reports, you'll be notified in writing when a company orders an

investigative report. This notice also will explain your right to ask for additional information

about the report from the company you applied to. If your application is rejected, you may

prefer to obtain a complete disclosure by contacting the CRA. Note that the CRA does not

have to reveal the sources of the investigative information.

How long can a CRA report negative information? - Generally seven years, with certain

exceptions:

- bankruptcy information can be reported for 10 years; information reported because of an

application for a job with a salary of more than $20,000 has no time limit; information

reported because of an application for more than $50,000 worth of credit or life insurance

has no time limit; information concerning a lawsuit or a judgment against you can be reported for seven years or until the statute of limitations runs out, whichever is longer.

Can anyone get a copy of my report? - No. Only people with a legitimate business need

can get your report.

Are there other laws I should know about? - If your credit application was denied, the

Equal Credit Opportunity Act requires creditors to tell you the specific reasons for your

denial. For example, the creditor must tell you whether the denial was because you have

"no credit file" with a CRA or because the CRA says you have "delinquent obligations." The

ECOA also requires creditors to consider, upon request, additional information you might

supply about your credit history. You may want to find out the creditor's reason for the

denial before you contact the credit bureau.

Where should I report violations of the law? - Although the FTC can't act as your

lawyer in private disputes, information about your experiences and concerns is vital to the

enforcement of the Fair Credit Reporting Act. Send your questions or complaints to: Correspondence Branch, Federal Trade Commission, Washington, D.C. 20580.

For a free copy of Best Sellers, a complete list of FTC publications, contact: Public

Reference Federal Trade Commission Washington, D.C. 20580 (202) 326-2222; TDD: (202) 326-2502

Personal Guarantee Letter: INDEPENDENT NEWSMEDIA INC. USA PERSONAL CONTINUING GUARANTY The undersigned jointly and severally, unconditionally and continually, guarantee to

______________________ dba/Independent Newsmedia Inc. USA (Hereinafter referred to

as "INI") the prompt payment of all of the obligations of _____________________ (Insert

Name of company) (hereinafter referred to as "Customer") to INI. The obligations of the

Customer which are guaranteed hereunder are all amounts due under the Customer's

contracts with INI, including without limitation, amounts due, administrative charges,

collection charges and interest. INI shall not be required to proceed against Customer to enforce any of its other remedies

or collect any amounts due before proceeding against the undersigned. The undersigned

agrees to pay all reasonable attorneys' fees, court costs, and other expenses incurred by

INI by reason of any default by Customer or guarantor. The undersigned waives notice of

acceptance hereof and all the other notices or demands of any kind to which the

undersigned may be entitled except demand for payment. The undersigned consents to any

extensions of time or modification of amount of payment granted to Customer and the

release and/or compromise of any obligations of Customer or any other obligors and/or

guarantors without in any way releasing the undersigned's obligations hereunder. This is a continuing guaranty and shall not be discharged or affected by your administrators,

representatives, successors, and assigns. Guarantor waives any right of subrogation,

indemnity, reimbursement and contribution by Customer. This Guaranty may be enforced

by or for the benefit of any assignee or successor of INI. Nothing shall discharge or satisfy

the undersigned's liability except the full performance and payment of all of the Customer's

obligations to INI, with interest. THE UNDERSIGNED CONSENTS TO THE PERSONAL

JURISDICTION OF THE COURTS OF THE STATE OF (INSERT APPLICABLE STATE) WITH

RESPECT TO ANY ACTION, GUARANTY, SETTLEMENT AGREEMENT, PROMISSORY NOTE OR

OTHER ACCOMMODATION OR AGREEMENT WITH CLIENT. THIS MEANS ANY LEGAL ACTION

FILED AGAINST THE CUSTOMER AND/OR GUARANTORS MAY BE FILED IN (INSERT

APPLICABLE STATE) AND THAT CUSTOMER AND/OR ANY OF THE GUARANTORS MAY BE

REQUIRED TO DEFEND AND LITIGATE ANY SUCH ACTION IN (INSERT APPLICABLE STATE).

Customer and all Guarantors agree that service of process by certified mail, return receipt

requested, shall be deemed the equivalent of personal service in any such action. Any legal action concerning the Agreement shall be governed by and construed according to

the laws of the state of (Insert applicable state). ____________________________________ GUARANTOR(S) SIGNATURE(S) _______________________________________

____________________________________ WITNESS SIGNATURE and DATE __________________________________________________ PRINT NAME PRINT NAME(S) __________________________________________________ GUARANTOR(S) SOCIAL SECURITY NUMBER __________________________________________________ GUARANTOR(S) ADDRESS, CITY, STATE AND ZIP

A. NOTIFYING THE GROUP Checks and credit card notices returned for "non sufficient funds" (NSF) are received by

iniaccount@newszap.com. Upon receipt, iniaccount@newszap.com posts the information on the network’s

NSF/chargeback log, notifying the credit team of the log’s update. The credit department

immediately post an adjustment to the adjustment network spreadsheet to charge back to

the customer the entire sum of the returned check or credit card (coded to 143000 or cash

account), plus an additional NSF fee of $35 (when applicable). B. NOTIFYING THE CUSTOMER The credit office must immediately notify the customer of a returned payment. A call should

be placed to the customer to arrange payment, advising that a credit hold has been placed

on the account until the returned payment plus service charge is satisfied. Confirm this

contact with the customer in writing. The appropriate sales team is notified by email of the

NSF and of the credit hold status. Suggested written correspondence for small NSF amounts: "Your check (or credit card payment), numbered 000, in the amount of $000, has been

returned to us by the bank. "We understand this may simply be a timing difference. Please remit the returned sum plus

a $35 service charge for a total of $000 to restore your credit status. If you cannot act

immediately, please give me a call. We do need to hear from you soon. Otherwise, this debt

will be turned over to a collection agency." In some instances, the returned check can be re-deposited. This must occur only after the

customer's bank has assured the availability of funds. Replacement or redeposit of funds from the customer should be deposited and recorded as

any other payment received. C. MAINTAINING RECORDS Customer accounts are noted in the advertising system when bad checks are

presented. For circulation, the credit specialist reviews the NSF log to see if/when there are

repeat offenders. Repeat offenders should be given mandatory cash with order (CWO) Media Plus Advertising System TOOLS FOR CREDIT AND COLLECTION The advertising system has tools available that can aid in maintaining credit policies and

assist in collections. The Media Plus Customer Relations Management (CRM) section filter certain ads to a holding

queue called TASKS once entered by the group’s ad support team. This ‘holding queue’

contains ads, whose customer account balances are in need of attention (i.e. CWO, past

due). The credit team then will release an ad in good standing. It also allow the credit

specialist to attach a note to the ad in TASK notifying the ad support team if there are

credit violations that require the customer to make payment prior to the ad being published

or killing the ad.

Special credit arrangements may be sought with the group’s vice president or publisher

which allows the ad to run even though it should be on "credit hold".

CREDIT STATUS

1. A customer who has been granted credit privileges should be identified with an Approved

credit status in the advertising system’s customer setup. 2. Some customers' payment histories do not warrant credit privileges. These accounts

should be identified with a CWO credit status. As stated in the Credit Policies section, these

accounts must prepay for all advertising. 3. Some customers' credit histories allow the collection team to issue credit privileges, but

require a specified limit that the account may not exceed. Such status should be identified

as Approved, but the credit limit should be entered on the account. 4. A customer's account may be placed on credit hold should collection efforts prompt the

application of this process. The credit status should be changed to CWO until the past due

balance is satisfied in full. See Credit Policies section. 5. When a customer fails to pay for advertising or internal printing, the account should be

forwarded to third party collections. See Collections section. The customer credit status

should be changed to Collect. If ads are entered, the system’s workflow will immediately

place the ad into the TASK queue, which can only be released by collect@newszap.com. 6. When an account is deemed to be uncollectible (See Collections section), the credit status

should be changed to Write-off once this process is complete. This prevents future

advertising on this account. A new account must be set up for future advertisements. This

account is also set up as prepayment. 7. There are always accounts that file for bankruptcy protection. The credit status for these

accounts should be immediately changed to Bankrupt, even if the account doesn't currently

have a balance. This will prevent future advertising from being entered for these accounts. HANDLING CWO AND CREDIT VIOLATORS IN THE PBS SYSTEM Any and all credit violators’ ad will fall into TASKS. At that time, collect@newszap.com will

follow up with the customer to obtain payment or notify the ad support team the ad must

be killed. Customer NOTES SYSTEM The Media Plus system includes the feature that allows an operator to post notes on the

customer’s advertising account, documenting any communications with the client.. These

notes can be viewed by by both the collection and advertising teams. The system also can

be used to document information that may be important about the account. This is a useful

to keep everyone up-to- date on the status or problems with a given account. COLLECTION CALL POLICY & COMMUNICATION The credit team (collect@newszap.com) handles accounts receivable and write-off

collections for each of Independent's three groups of newspapers and printing divisions'. Based on monthly aging reports, collect@newszap.com will Make quick, courteous calls to

all accounts that have slipped into the over 30-day balance category. The credit team

will also make courteous calls to customers whose current balance will move to 30

to make sure the customer has what is needed to pay their invoice It is important to initiate collection efforts at the 30-day delinquency level. Purpose of this

30-day service call is to ensure no "billing" or "rating" problems that would cause the

advertiser to hold up payment. If no problems exist, collect@newszap.com should request a

commitment for payment-in-full or a specified amount to be delivered on a specific date.

Normal procedures should expect payment-in-full within 10 days. If an account has a problem with the billing or needs tear sheets, the credit team should

research the problems and forward any necessary information on a timely basis.

Communication should be maintained with the sales team through e-mail. Any rating

questions should be documented fully and passed along to billteam@newszap.com . . For collection purposes, a record of all contacts, commitments, and subsequent actions will

be maintained in the billing system’s customer note section. Every contact or attempt to

contact a customer should be documented. A network collection folder is maintained for

each account that require additional collection efforts. . This folder should include copies of

all collection correspondence (i.e. letters),that facilitate the collection process, and provide

necessary documentation for later legal action or write-off processes. Follow-up calls are placed and the customer reminded that credit will be suspended if

payment is not received by the period specified by the credit specialist. The credit team

politely informs the customer the balance needs to be resolved quickly, which may also

include a payment arrangement. This can be resolved immediately with payment of credit

card or check by phone. IF the customer insists the check will be placed in the mail, the

customer is given a period of time, which may be five to 10 days. All payment arrangement

are offered as credit card and/or check by phone. The account should be politely advised

that Independent will continue to run ads if submitted with cash in advance, plus a

minimum 10%of the past due balance. The credit manager should also explain that credit

may be restored once the account has paid all previous balances, provided they haven't

gone to third party collections. If a collection problem cannot be resolved through the routine call method, collections

letters are mailed such as a 10-day demand letter. This letter, which is mailed certified

return receipt should provide the account a 10-day window in which to resolve the

outstanding balance. The letter also informs the account the overdue balance will be

forwarded to a 3rd party collection agency or a court for legal action. Unresolved collection accounts are forwarded to the credit director, who sends an email or

final letter to develop a win-win relationship in resolving the outstanding balance. The letter

requests a response within five (5) business days. If no response is received, the account is

forwarded to a 3rd party collection agency at the end of the five (5) window. Account

adjustments for finance charges may be used as a negotiation tool to collect an outstanding

balance. However, a credit manager should resist removing finance charges from accounts

too hastily. Billing Dispute Text (4c. credit/collection policy) This email is to notify ad consultant when a customer disagrees with a bill. The email is sent

to the group ad team for review and follow up.

Customer Dispute form:

TELL THE CUSTOMER: "We're very sorry you are having a problem and we intend to resolve

it as soon as possible. To help us do that, we need some information:

1. Account number or name to which ad is billed:

2. Your name and email address:

3. A phone number where we can contact you:

4. Number of sales representative:

5. Name of Publication(s) customer’s ad ran in:

6. Nature of problem:

7. Phone number or person/department you have already contacted about this

matter: (knowing WHICH 800 number the customer called is VERY important):

TELL CUSTOMERS: "We will get you answers and someone will get back to you this

afternoon or no later than tomorrow morning before noon. Thank you for calling and again,

we are VERY sorry for the problem."

NOTE to TEAM HANDLING THIS COMPLAINT:

8. We received the following complaint today and we have promised the customer a resolution no later than noon _________.

9. Please use "reply to all" when you send email notification that the customer has been

contacted and the problem addressed. Please include a brief description of how the problem was handled.

Thanks,

Credit Specialist Name

collect@newszap.com

__________________________ 10 DAY DEMAND LETTER: Mailed or emailed to client as follow up correspondence after Collection Phone Calls Made

w/no response: (DATE) (ACCOUNT NAME) (STREET ADDRESS)

(CITY, STATE, ZIP) Re: Final demand for payment, account #_____________________ Dear __________: You placed ads in [name of newspaper(s)] on [dates ads ran]. We sent you invoices for this

advertising on [dates invoices were sent]. Since then, we have made several good faith attempts to contact you about your

outstanding balance, yet we still have not received your payment. Your balance,

$___________, is now seriously past due balance. While our wish is to maintain a mutually beneficial business relationship, you have left us no

choice but to make this FINAL REQUEST for payment in full. If payment is not made within

10 days from the date of this letter, your account will be turned over to Independent's

outside collection agency. All personal and business information on file in our office will be

reported to all major credit bureaus. Failure to respond could lead to legal action. Once

court documentation has been submitted, you will be responsible for the full balance owed

including finance charges and all court fees. We remain hopeful that you will act promptly and forward your check in full. But to avoid

further action, we must hear from by 00/00/00. Thank you for your immediate attention to this matter. Sincerely, (name) Corporate Credit Specialist Independent Newsmedia Inc. USA 800-426-4196, Ext__________ Email: ____________________ Letter from Credit Director (final letter/email)

DATE

Account Name

Account Street Address

City/State/Zip

RE: Advertising Account # _________________

Publication __________________________

Dear Accounts Payables:

Your account has been forwarded to me in order to make a determination on whether your account, ___________________should be turned over to an outside collection agency.

Please know that I’d prefer not to take this type of action, since this will mean your account

will be flagged with an adverse credit rating by the credit bureaus (i.e. Equifax,

TransUnion). If you are having financial difficulties, please know that we will work with you

and set up a payment arrangement plan. However, in order to do this, we need to hear from you.

Please do not ignore our calls! Let’s re-establish a win-win partnership. Your timely response is requested by _______________ to avoid further action.

Regards,

Corporate Credit Director

800-426-4192 (Ext 8206)