RP11/94-95

Newspaper Licensing and

Distribution Systems in Hong Kong

Research and Library Services Division

Legislative Council Secretariat
July 1995
 Newspaper Licensing and Distribution Systems in Hong Kong

Introduction

This research is conducted at the request of the LegCo Panel on

Information Policy made on 28 June 1995. In view of the short timeframe and
the difficulties in collecting information on distribution practices, it is aimed to
provide general information on the newspaper licensing and distribution
systems in Hong Kong.

2. This paper is divided into two parts: Part I is on the registration of

newspapers and licensing of newspaper distributors. Part II gives a brief
account of the newspaper distribution system in Hong Kong. Information on
the systems and practices in other countries are provided as far as possible.

Part I: Registration of Newspapers and Licensing of Newspaper Distributors

Registration of Local Newspapers Ordinance (CAP. 268)

3. The licensing framework for local newspapers is provided for by the

Registration of Local Newspapers Ordinance (CAP. 268) ("ROLNO") and its
subsidiary Regulations. Until 1987, the Ordinance was known as the Control
of Publications Consolidation Ordinance. Enacted in 1951, it had
considerably broader powers then. Major amendments were passed in 1987,
with minor ones in 1988, whereby parts of the Ordinance were repealed,
amended or added. As a result, its purpose is simply "to provide for the
registration of local newspapers and news agencies and the licensing of
newspaper distributors and for matters connected therewith".

Definition of newspaper

4. Under ROLNO, a newspaper is any paper or publication available to

the general public, which (a) contains "news, intelligence or occurrences" or
remarks, observations and comments related thereto or to any other matter of
public interest, and (b) is produced for sale or free distribution and published
either periodically or in parts and numbers at intervals not exceeding 6
months. Most magazines would be included under this definition.

5. Some publications, such as academic journals, almanacs, cartoons

and comic strips, financial, economic and statistical reports, racing tips are not
classified as newspapers. A complete list of excluded publications is in
Appendix I.

6. A local newspaper is one printed or produced in Hong Kong.

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Registration of newspapers

7. Under ROLNO, every local newspaper has to be registered with the

Registrar of Newspapers, who is, by appointment of the Governor, the
Secretary for Home Affairs. The licensing and administrative duties are
delegated to the Deputy Registrar of Newspapers, who is the Commissioner
for Television and Entertainment Licensing. In practice, the registration of
newspapers is administered by the Television and Entertainment Licensing
Authority (TELA), while the Home Affairs Branch is responsible for the review
of policy issues from time to time.

8. The only requirements for the registration of a local newspaper are that
the following particulars be furnished and their correctness certified by an
informant.
In respect of the newspaper -
- name of newspaper
- address
- frequency of publication

In respect of the newspaper's proprietor, printer, publisher and editor

respectively -
- name
- business address
- Hong Kong identity card number (or passport or travel
document number, or business registration number in the
case of a company or other body corporate)
- signature or seal

9. In accordance with Section 3 of the Newspapers Registration and

Distribution Regulations (subsidiary regulations to ROLNO), the above
particulars are to be furnished on a prescribed form, a sample of which is in
Appendix II. If any change occurs or any inaccuracy is discovered in the
particulars supplied at registration, the substituted particulars have to be
certified correct and furnished within 7 days.

10. In addition to the above statutorily required particulars, TELA also asks
the informant to fill out a personal particulars form (sample in Appendix III) for
reference and statistical purposes. Apart from personal particulars such as
name, identity card or passport number, place and date of birth etc., and the
name and language of the proposed newspaper, the informant is required to
indicate the nature of the proposed newspaper and whether he has previous
experience in publishing business. The latter is to enable TELA to know
whether the proposed newspaper is related to any defunct newspapers.

11. The qualifications of an informant are not specified. According to

TELA, the informant can be the proprietor, printer, publisher, editor of the
proposed newspaper or any person authorised by one of them.

12. An annual fee of $785 is payable for each registered newspaper. The
publisher or printer has to deliver to the Registrar a copy of the newspaper

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within one day after it is published. The law also requires that the printer's
name to appear on the front or back page of the local newspaper.

Government control

13. There is no vetting by the Administration in the registration process

other than a check to ensure that the name of the proposed newspaper is not
identical to that of a local newspaper already registered. The main purpose of
registration is to have a record for ascertaining persons responsible in the
event of libel or copyright suits.

14. ROLNO does not contain any provisions restricting the proprietor of a
local newspaper from acquiring an interest in any company without the
approval of the relevant authority. Nor does ROLNO restrict foreign share-
holding in a local newspaper. There are also no provisions under the
Companies Ordinance (Cap. 32) to restrict a company incorporated or
registered under it from owning a local newspaper.

15. However, other ordinances may apply to restrict cross-media

ownership of newspapers. Under section 17C of the Television Ordinance
(Cap. 52), a television licensee should not acquire an interest in any company,
including a company formed for newspaper business, without the approval of
the Broadcasting Authority.

16. No attempt is made to check the criminal record of the proprietor. If a

newspaper company is a listed one, it is required under Section 3 of the
Securities (Stock Exchange Listing) Rules (Cap. 333) to comply with the rules
and requirements of the Hong Kong Stock Exchange. Currently, the directors
of the company are required under the rules of the Exchange to declare
whether they have been convicted for specified offences. The Stock
Exchange is reviewing the qualifications required of a director of a listed
company. One of the issues being reviewed is whether a person with
previous convictions can qualify as a director.

17. As of 30 June 1995, there were 725 local newspapers registered under
the Ordinance. 82 of these are newspapers - of which 39 are Chinese
language dailies and 4 English language dailies, and 631 periodicals.

Licensing of newspaper distributors

18. Anyone who wants to distribute newspapers for sale in Hong Kong is
required to obtain a licence under the Newspapers Registration and
Distribution Regulations. In applying for a licence, one has to inform the
Newspaper Registration Section of TELA in writing the names and frequency
of publication of the newspapers or magazines they intend to distribute. In
addition, he has to provide his particulars including name, business address,
identity card number and distribution areas and two photographs. An annual
licence fee of $785 is also required. The applications are not vetted by TELA.
It is indicated in TELA's performance pledge that the licence can be issued
within 30 minutes to those who apply in person.

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19. 'Distributor' is not defined under the law, and therefore carries its
dictionary meaning. The latest TELA register shows that there are 45
licensed distributors in Hong Kong. This number includes distributors of
periodicals and magazines since "newspapers" is defined as any publication
or news published at intervals not exceeding six months.

Registration and regulation of newspapers overseas1

20. A study of practices in Australia, Austria, Canada, France, Germany

Netherlands, Norway, Spain, Sweden, UK and US showed that government
approval is not required to launch a newspaper in any of the countries.

21. As in Hong Kong, a few of the countries require newspapers to be

registered, but the authorities do not have the power to refuse registration,
and it has been at least decades since the registration requirements were
used as a means of censorship. The requirements may include the filing of
the names and addresses of the publisher, printer or the person legally liable
for the publication's contents. Another requirement is to include in the
newspaper the names and addresses of the publisher and printer. Most of
the countries studied require a copy of the newspaper to be deposited with a
stipulated depository.

22. In most countries studied, there has been a marked increase in

concentration of ownership among the press. France and Germany have
enacted laws to prohibit such activity. In several European countries and the
US, mergers and acquisitions among press companies come under anti-trust
and company laws.

23. Five countries (Australia, Canada, Norway, the UK and the US) restrict
cross-ownership among different types of media. Several countries
(Australia, Canada, France and Spain) subject foreigners’ acquisition of
shares in press companies to government review or regulation. In Australia,
Canada and Spain, such control is largely administrative in character.
However, France has barred foreigners from owning more than 20 per cent of
a press enterprise since 1984.

Part II: Newspaper Distribution System

Major types of distribution system

24. Newspaper distribution system and practices in Hong Kong are not well
documented. Statistics on the number of newspaper distributors and the
number of newspapers they distribute are not available. Information on the
role and relationship of different types of distributors is brief and general.
There is also a lack of information on the detailed distribution practices such
1
Comparative Analysis of Press Law in European and Other Democracies by Sandra Coliver,
Press Law and Practice, published by Article 19 for the United Nations Educational Scientific
and Cultural Organization, March 1993, pp. 260-262

4
as the quantity and pricing of newspapers for different types of distributors
since the information is regarded as commercially sensitive.

25. The Division undertook different data collection activities to gather

information from various parties involved in newspaper distribution work.
Details of the activities and response are given in the Appendix IV. The
response rate so far is low.

26. Based on limited information available, a general description of the two

main distribution channels and practices for local daily newspapers in Hong
Kong is given below. An update will be prepared when more response is
received.

Distribution to newspaper hawkers

27. According to the "Report and Recommendations of the Urban Council

Working Party on Hawker and Related Policies" published in 1987, newspaper
hawkers refer to on-street newspaper vendors (p. 37). Latest statistics show
that there are 822 licensed newspaper hawkers in the urban area and 183 in
the New Territories.

28. Almost all local Chinese newspapers do not have their own distribution
team. They rely on distributors or wholesale agents to deliver the newspapers
to the newspaper hawkers in the territory. Distributors can be divided into
three main categories, each is described below.

Main distributors

29. A main distributor has an exclusive right to handle distribution for a

particular newspaper. There are only a few main distributors in Hong Kong.

30. A main distributor may allocate newspapers to area distributors and

sub-distributors or it may deliver the papers to hawkers by themselves. There
is at least one main distributor known to deliver newspapers with its own staff
and trucks.

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31. Depending on resources and manpower, a main distributor of a
newspaper may also act as an area distributor for other newspapers.

Area distributors

32. Most newspapers allocate their papers to several distributors, each of

which covers distribution in a certain area. Such distributors are generally
referred to as area distributors but they do not necessarily cover the same
area for all the newspapers they distribute.

33. Like main distributors, area distributors may give some newspapers to
sub-distributors and deliver some to newspapers hawkers directly. In our
survey, one area distributor which distributes two newspapers in Wanchai,
Causeway Bay and North Point also allocates some newspapers to sub-
distributors.

34. Main and area distributors act as a communication link between

newspaper hawkers and newspaper companies. Everyday, newspaper
hawkers inform the distributors the quantity of each newspaper they need for
the next day. The distributors will pass on the information to various
newspapers which will then decide on the print run for the next day.

Sub-distributors

35. As mentioned above, main and area distributors give newspapers to

sub-distributors who in turn deliver them to newspaper hawkers at dedicated
locations.

36. Unlike main distributors or area distributors, sub-distributors do not

have a direct or formal relationship with newspapers. They play the role of
delivering newspapers from distributors to newspaper hawkers.

37. Some newspaper hawkers also act as a sub-distributor by allocating

some of the newspapers they obtain from the main or area distributors to
other hawkers.

38. Main distributors, area distributors, sub-distributors and hawkers get

newspapers at a discount of the retail price but the actual percentage of
discount varies. An article2 in a Chinese newspaper provides a rough
indication on the pricing. According to the article, main and area distributors
obtain newspapers at $3 per copy and supply them to sub-distributors at
$3.175 per copy and to hawkers at $3.25 per copy. If newspaper hawkers
obtain newspapers from sub-distributors, the price is $3.5 per copy.

2
Ming Pao Daily News, 9.1.1995

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Distribution through supermarkets and convenience stores

39. An alternative newspaper distribution channel through supermarkets

and convenience stores has emerged in recent years. The quantity of
newspapers distributed through this channel is not large at the moment but
this distribution channel may grow in importance as the number of
convenience stores proliferates.

40. Supermarkets and convenience stores operate in chains with their

outlets scattered all over Hong Kong. Nearly all3 the outlets of the two major
chains of convenience stores sell newspapers. One chain which has 324
outlets sells 19 local Chinese dailies. Another chain which has 113 outlets
sells 13 local Chinese dailies. A big supermarket chain sells newspapers in
all of its 165 outlets. It sells nine local Chinese dailies.

41. Unlike newspaper hawkers, outlets of convenience stores and

supermarkets do not obtain the newspapers from respective area distributors,
except for five Chinese dailies. Instead, their head office negotiate directly
with newspaper companies on the pricing and quantity of newspapers
required. The newspaper companies then arrange a transport agent to deliver
newspapers to all the outlets of the convenience stores and supermarkets.

42. The exact wholesale price of newspapers for convenience stores and
supermarkets is not known but is higher than that for distributors since
newspaper companies have to pay for the delivery service.

Difference between the two distribution channels

43. Convenience stores and supermarkets have different working practices

from newspaper hawkers. Convenience stores and supermarkets require
proper documentation such as delivery notes while newspaper hawkers do
not. They pay the bill once every month or few months while hawkers usually
clear the bill within a few days. Also, convenience stores and supermarkets
require unsold newspapers to be returned to individual newspaper companies
while hawkers do not.

Concluding remarks

44. The purpose of ROLNO is to provide a simple licensing framework that

poses no impediment to press freedom while maintaining a set of public
records that helps to establish the appropriate responsibilities of the press
itself. The practice appears to be in line with those in the mainstream of
industrialized countries, while the degree of regulation of ownership is, if
anything, smaller in Hong Kong than in those countries generally.

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except one or two remote outlying islands

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45. Newspaper distribution has a very complicated system. It involves
thousands of people working in the early hours packing and delivering
newspapers to hawkers every day. The flow of newspapers is vertical with
newspapers passing down from people at the level of main or area
distributors eventually to newspaper hawkers. While these people belong to
many different companies, long-established working practices have ensured a
co-ordinated and efficient flow.

46. A different kind of network has emerged as more and more

newspapers are distributed through supermarkets and convenient stores.
The flow of newspapers is horizontal, with transport agents taking newspapers
to every individual outlet of convenience stores or supermarkets. This has
provided new opportunities for those who are not familiar with working
practices and role of different kinds of distributors to join the distribution
system.

RP11/94-95
Research and Library Services Division
Legislative Council Secretariat
July 1995

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 Appendix I

Publications excluded from Definition of Newspaper

(Schedule to Registration of Local Newspapers Ordinance)

1. Academic journals.
2. Almanacs.
3. Cartoons and comic strips.
4. Collections of photographic images with or without captions.
5. Commercial advertisements and commercial advertising circulars and
brochures.
6. Commercial circulars.
7. Company and partnership reports and company prospectuses.
8. Consumer information and reports.
9. Election pamphlets and posters.
10. Financial, economic and statistical reports.
11. Information sheets and newsletters relating to clubs, educational
institutions, professional associations, societies, trade unions and other
organisations.
12. Maps, charts and tables.
13. Price lists.
14. Public speeches and statements.
15. Racing tips, racing form reports and other tabloid materials.
16. Religious materials.
17. Sales catalogues.
18. Sheet music.
19. Trade catalogues and journals.
20. Travel brochures.
 SAMPLE
Appendix II

REGISTRATION OF LOCAL NEWSPAPERS ORDINANCE

(Chapter 268)

NEWSPAPERS REGISTRATION AND DISTRIBUTION REGULATIONS

PARTICULARS OF PROPRIETOR, PRINTER, PUBLISHER

AND EDITOR OF LOCAL NEWSPAPER

Name of local newspaper

Address of local newspaper

Frequency of publication
(half-yearly/quarterly/monthly/fortnightly/weekly/daily or otherwise)

Full name of proprietor

Business address of proprietor
Tel.:
*Hong Kong identity card no. of proprietor
Signature or seal of proprietor

Full name of printer

Business address of printer
Tel.:
*Hong Kong identity card no. of printer
Signature or seal of printer

Full name of publisher

Business address of publisher
Tel.:
*Hong Kong identity card no. of publisher
Signature or seal of publisher
 SAMPLE

Full name of editor

Business address of editor
Tel.:
*Hong Kong identity card no. of editor
Signature of seal of editor

I certify that the above particulars and my description are correct.

**Signature of informant:

Description of informant:
(proprietor/printer/publisher/editor or otherwise)

Date:

Note: *(i) Where no Hong Kong identity card is held a passport or other travel document
no. should be inserted.
In the case of a company or other body corporate the company registration no.
should be inserted.

**(ii) In the case of a company or other body corporate the informant should be a
director, manager, secretary or other officer of that company or body
corporate.
In the case of a firm or partnership the informant should be a partner of that
firm or partnership.
 SAMPLE
Appendix III

REGISTRATION OF LOCAL NEWSPAPERS ORDINANCE CAP 268

NAME: (MR./MRS./MISS/MS.)

HK IDENTITY CARD NO./PASSPORT NO. PLACE AND DATE OF BIRTH:

OFFICE NAME AND ADDRESS: POSITION HELD: OFFICE TEL. NO.:

PAGER NO.:

RESIDENTIAL ADDRESS: RESIDENTIAL TEL. NO.:

NAME OF THE PROPOSED NEWSPAPER: LANGUAGE OF THE PROPOSED

NEWSPAPER:

NATURE OF THE PROPOSED NEWSPAPER:

PREVIOUS EXPERIENCE IN PUBLISHING BUSINESS:

I confirm that I have read the "How to apply for Registration of a local
newspaper/periodical" and am satisfied that the proposed newspaper is a local newspaper
as defined in the Registration of Local Newspapers Ordinance, Cap. 268.

Signature of Informant:

Date:
 Appendix IV

Data Collection Methodology and Results Up to 21.7.1995

Interview with the Newspaper Society of Hong Kong

1. The Research and Library Services Division approached the

Newspaper Society of Hong Kong for an interview on the newspaper
distribution practices. The Society turned down the request and advised
verbally that it did not have information on the overall newspaper distribution
system in Hong Kong. The Society further advised that it could not provide
any information on individual newspapers since it would involve commercially
sensitive information.

Questionnaire for newspapers

2. Failing to obtain information from the Newspaper Society of Hong

Kong, the Division sent a questionnaire to individual newspapers to solicit
information. Due to the tight schedule and resource constraint, the Division
limited the survey to five Chinese newspapers. They were newspapers with
the highest readership measured by the SRH media index between July 1994
and December 1994. Up to 21 July 1995, three newspapers have responded
to the questionnaires. One newspaper has seven area distributors covering
the areas described below.

1. Island East
2. Yau Ma Tei, Tsim Sha Tsui and Tsuen Wan
3. West Kowloon and Macau
4. Mongkok
5. Central, Kwun Tong and the New Territories
6. The New Territories
7. Kowloon East

3. Another newspaper responded to our survey has eight area distributor

covering the areas described below.

1. Wanchai and Island East

2. Tsuen Wan
3. Tsuen Wan and Sha Tin
4. Kowloon East
5. Yuen Long, Tuen Mun and Sham Shui Po
6. Sha Tin, Yau Ma Tei, Tsim Sha Tsui and Mong Kok
7. Kowloon East, Yau Ma Tei and Mong Kok
8. Yau Ma Tei, Tsim Sha Tsui and Mong Kok
4. The third newspaper responded has six distributors covering the
following areas in Hong Kong.

1. Central District, Island South, Sheung Wan, Western, Sha Tin,

Cheung Sha Wan, Lai Chi Kok, Shum Shui Po, Shek Kip Mei,
Tai Kok Tsui, Lai King, Kwun Tong, Tsz Wan Shan, San Po
Kong and Wong, Tai Sin
2. Island East, Wanchai, Happy Valley, Chai Wan, Causeway Bay,
North Point, Quarry Bay, Shau Kei Wan
3. Kwai Chung, Tsuen Wan, Tsing Yi, Yau Ma Tei, Jordan, Tsim
Sha Tsui
4. Yau Tong, Lam Tin, Sai Kung, Kowloon Bay, Choi Hung
5. Kowloon City, Prince Edward, Hung Hom, Tokwawan
6. Homantin, Mong Kok, Prince Edward

Questionnaire for distributors

5. The Division sent a second questionnaire through the Television and

Entertainment Authority to 45 licensed distributors on the register of the
Newspaper Registration Section of TELA. Up to 21 July 1995, nine have
responded.

6. Among the respondents, two provide information relevant to our

research project.

7. One of them distributes eight newspapers including local Chinese

newspapers, a English daily and some newspapers from China. It distributes
in the Island East area. It also distribute some newspapers to sub-
distributors.

8. The second distributor distributes seven newspapers in Yau Ma Tei,

Tsim Sha Tsui and Tsuen Wan. It delivers newspapers directly to hawkers
and does not give newspapers to sub-distributors.

9. The response of seven other distributors is given in the table below.

Response Do not distribute Do not distribute Closed down

newspapers local Chinese
newspapers
Number of 3 3 1
newspapers

10. Based on information supplied by the newspapers, the same

questionnaire was sent to nine others distributors which are not on the list
obtained from TELA. Two have responded so far.
11. One distributes two newspapers in Kowloon East. It delivers one
newspaper directly to hawkers. It distributes some of the second newspaper
to hawkers and some to sub-distributors.

12. Another distributor distributes three newspapers in Mongkok area. For

all three newspapers, it distributes them both directly to hawkers and to sub-
distributors.

Questionnaire for supermarkets

13. The Division sent a third questionnaire to two major supermarkets and
two convenience stores in Hong Kong to solicit information on the alternative
distribution channel for newspapers. Up to 21 July 1995, two major chains of
convenience stores and a supermarket chain have responded but not the
other supermarket chain. The results are described in the section on
distribution through supermarkets and convenience stores.

14. All three questionnaires are attached in Annexes I to III.

 SAMPLE
Annex I
Page 1

(Questionnaire for newspapers)

Research and Library Services Division

Legislative Council Secretariat
(Tel: (852) 2869-9621 Fax: (852) 2525-0990)

Questionnaire for the Research on Newspaper Licensing and Distribution Systems

in Hong Kong

Part I

Name of your company Contact person for follow-up Contact telephone number

Part II

1. How many distributors do you use to distribute your newspaper?

2. What are the geographical areas covered by your distributors?

Name of distributors Areas covered

(optional)

1.

2.

3.

4.

5.
 SAMPLE
Annex I
Page 2

Part III

If possible, please supply us the following in respect of your distributors to facilitate our
collection of information from them.

Name Contact Telephone Address

person

* * End of Questionnaire * *

Thank you very much for your assistance. We will not reveal your identity in our research
paper when using information you supply us.

5
 SAMPLE
Annex II
Page 1
(Questionnaire for distributors - translated version)
Research and Library Services Division
Legislative Council Secretariat
(Tel: (852) 2869-9621 Fax: (852) 2525-0990)

Questionnaire for the Research on Newspaper Licensing and Distribution Systems

in Hong Kong

Part I

Name of your company Contact person for follow-up Contact telephone number

Part II

Please provide the following information for each of the local daily newspaper you
distribute.

1. 2. 3.

Q1 Name of newspaper
(optional)

Q2 Distribution basis*
(1) Exclusive/
(2) Non-exclusive

Q3 From whom do you receive

the newspapers you
distribute?*
(1) Newspapers
(2) Other distributors

Q4 To whom do you send your

newspapers?* (1)
Newspaper vendors (2)
Other distributors

Q5 What are the geographical

areas covered for each
newspapers?

Q6 What are the reasons for

further distribution?
[If answer to Q4=(2)]

Choose (1) or (2)

1
 SAMPLE
Annex II
Page 2

Part II cont.

4. 5. 6.

Q1 Name of newspaper
(optional)

Q2 Distribution Basis*
(1) Exclusive/
(2) Non-exclusive

Q3 From whom do you receive

the newspapers you
distribute?*
(1) Newspapers
(2) Other distributors

Q4 To whom do you send your

newspapers?* (1)
Newspaper vendors (2)
Other distributors

Q5 What are the geographical

areas covered for each
newspapers?

Q6 What are the reasons for

further distribution?
[If answer to Q4=(2)]

* Choose (1) or (2)

2
 SAMPLE
Annex II
Page 3

Part II cont.

7. 8. 9.

Q1 Name of newspaper
(optional)

Q2 Distribution Basis*
(1) Exclusive/
(2) Non-exclusive

Q3 From whom do you receive

the newspapers you
distribute?*
(1) Newspapers
(2) Other distributors

Q4 To whom do your send

your newspapers?*
(1) Newspaper vendors
(2) Other distributors

Q5 What are the geographical

areas covered for each
newspapers?

Q6 What are the reasons for

further distribution?
[If answer to Q4=(2)]

* Choose (1) or (2)

Please use a separate sheet if you distribute more than nine newspapers.

* * End of Questionnaire * *

Thank you very much for your assistance. We will not reveal your identity in our research
paper when using information you supply us.

3
 SAMPLE
Annex III
Page 1
(Questionnaire for supermarkets)

Research and Library Services Division

Legislative Council Secretariat

(Tel: (852) 2869-9621 Fax: (852) 2525-0990)

Questionnaire for the Research on Newspaper Licensing and Distribution Systems

in Hong Kong

Part I

Name of your company Contact person for follow-up Contact telephone number

Part II

1. How many outlets do you have in Hong Kong?

2. How many of the outlets sell local Chinese newspapers?

3. Which are the local daily newspapers they sell?

4. What is the quantity of each local Chinese newspapers they sell every day?
 SAMPLE
Annex III
Page 2

5. From whom do your outlets get the newspapers? Please choose (a) or (b).

a. directly from the newspapers

b. from newspaper distributors

6. For outlets that do not sell newspapers, what are the reasons for not doing so?

* * End of Questionnaire * *

Thank you very much for your assistance. We will not reveal your identity in our research
paper when using information you supply us.