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 INIs 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 days 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 groups 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 groups 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 groups 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 companys 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. Youll 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 wont 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, youll 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 networks
NSF/chargeback log, notifying the credit team of the logs 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 groups 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 groups 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 systems 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 systems 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
customers 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 systems 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) customers 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 Id 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! Lets 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)