Independent House, 27-32 Talbot Street, Dublin 1 | www.inmplc.com

Joint Committee on

Communications, Climate Action and Environment

______________________

Submission by

Independent News & Media plc

______________________

6th February 2017

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EXECUTIVE SUMMARY

1. Independent News & Media plc (“INM”) has been invited to address the Joint Committee on

Communications, Climate Action and Environment in relation to the media merger examination of

the proposed acquisition of CMNL Limited (“CMNL”), formerly Celtic Media Newspapers Limited, by

INM (Independent News & Media Holdings Limited) by the Broadcasting Authority of Ireland

(“BAI”).

2. The agreement for the sale and purchase of the entire issued share capital of CMNL Limited by INM

was executed on 2nd September 2016. In line with the media merger requirements detailed in the

Competition Acts 2002-2014, INM and CMNL jointly submitted a notification to the Competition and

Consumer Protection Commission (“CCPC”) on 5th September 2016. On 10th November 2016 the

CCPC determined that the transaction would not lead to a substantial lessening of competition in any

market for goods or services in the State and the transaction could be put into effect subject to the

provisions of 28C(1) of the Competition Acts 2002-20141.

3. On 21st November 2016, INM and CMNL jointly notified the Minister of Communications, Climate

Action and Environment of the Proposed Transaction seeking approval and outlining the reasons

why the Proposed Transaction would not be contrary to the public interest in protecting plurality of

media in the State. On 10th January 2017, the Minister informed the parties of his decision to request

the BAI to undertake a review as provided for in Section 28D(1)(c) of the Competition Acts 2002-

2014.

4. INM believes the Proposed Transaction will deliver a positive outcome for CMNL and its titles for the

following reasons:

The positive determination by the CCPC following a detailed review.

The Proposed Transaction will secure quality jobs in regional areas.

Despite the continuing pressures on the Industry the importance of local newspapers for

INM is not diminished.

CMNL is facing material financial challenges which INM can alleviate.

5. Along with the above, INM believes that the Proposed Transaction will not be contrary to the public

interest in protecting plurality of media in the State for the following reasons, which are discussed in

further detail in this document:

No geographic overlap between INM and CMNL titles and the existence of competing

newspapers in each area.

Editorial independence of the editors of all regional titles affected will continue following the

Proposed Transaction.

CMNL’s readers will see no discernible difference in their newspaper.

The Proposed Transaction will secure the future of CMNL’s newspapers.

Frank Mulrennan, Chief Executive of CMNL, will join INM and continue to lead CMNL and its

employees.

1 Determination of CCPC M16/044-INM/CMNL 10th November 2016, Paragraph 75

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SECTION 1 – INTRODUCTION

About CMNL

6. Celtic Media Group was formed in 2012 through a management buy-out, led by current Chief

Executive Frank Mulrennan, from a receivership event involving the former Scottish investor owners

and Lloyds Bank. In addition to securing many jobs, Celtic Media allocated 21% of the shares in the

Company to its editors, sales managers and production managers. These staff members will

therefore benefit from the proceeds of sale.

7. CMNL Limited, the publishing division of Celtic Media Group, employs approximately 99 people and

publishes five paid-for and two free newspapers. Its paid-for titles comprise The Connaught

Telegraph, Westmeath Independent, Westmeath Examiner, Meath Chronicle, and The Anglo Celt, and

its free newspapers comprise Your Forum and Offaly Independent. These newspapers have c. 950

years of combined history and deep commitment to their communities.

8. In addition, CMNL offers pre-press services (outsourced graphic design, page layout and digital

services) to independently-owned titles such as The Nenagh Guardian, The Tuam Herald, Cork

Independent and Galway Independent, enabling these titles to operate efficiently and, more

importantly, with certainty.

About INM

9. Independent News & Media plc is a media company in Ireland and Northern Ireland. All of the

Group’s operations are based on the island of Ireland and it provides direct employment to c. 600

people in the State, a further c. 215 in Northern Ireland and many more indirectly.

10. INM’s newspapers far predate the existence of INM itself with papers such as The Sligo Champion

(founded 1836), The Kerryman (1904) all well-established papers. The Irish Independent has

recorded Irish and international matters for the Irish people since 1905. Other papers in INM’s

business are also household names, such as the Sunday Independent, The Herald, Sunday World,

Wexford People and other regional titles. All of these titles have maintained their identity and

continue to have a unique voice speaking to their readers from within INM.

11. INM’s current weekly regional newspapers are published in counties Louth, Wexford, Wicklow, Cork,

Kerry, and Sligo. None of these catchment areas represent any overlap with any of the titles in the

Proposed Transaction to acquire CMNL. This was recognised by the CCPC itself in its determination

where it found that the Proposed Transaction “does not give rise to horizontal overlaps in different

local/regional areas for the publication of local/regional newspapers based on readership” except for

minor spill-over sales2.

INM history

12. The company was formed as Independent Newspapers Limited in 1904 by William Martin Murphy,

the publisher of the Irish Independent. The Irish Independent was the direct successor to the Daily

Irish Independent, a newspaper that originated in the 1890’s.

13. In an early sign that consolidation has always been a factor in print publishing (and will be necessary

to remain so), in 1924, the traditional nationalist newspaper, the Freeman’s Journal, merged with the

Irish Independent, and until 1986 the paper's masthead contained the words "incorporating the

Freeman's Journal". Over the following decades, the Company expanded into regional press

acquiring the Drogheda Independent, the Wexford People series of titles, The Corkman, The Kerryman

2 Determination of CCPC M16/044-INM/CMNL 10th November 2016, Paragraph 42

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and The Sligo Champion. All of these regional titles make a valuable contribution to the INM business

and their inter-dependency with the national titles in sharing back-office services, network and

printing plants allow them to plan for a longer future as printed newspaper and safeguard jobs.

14. In the late 2000’s INM’s publishing assets, along with the industry as a whole, suffered a material

decline in revenue. In 2008, INM announced losses before tax of €161.4m. In early 2009, the

Company failed to reach agreement with bondholders in relation to €200m bond which cast doubt

on INM’s ability to continue as a going concern3. Following material support from shareholders, the

Board, management and staff, the company underwent major and complex restructuring. Between

2009 and 2015 it was necessary for INM to dispose of multiple foreign holdings in markets such as

Germany, UK, South Africa and Australia. All proceeds of these transactions were used to reduce and

ultimately clear outstanding bank debt.

15. In the face of all these challenges, the quality of INM’s journalistic output has been recognised in the

achievement of its editorial team in winning numerous awards.

INM’s belief in Print & Publishing in Ireland

16. By 2015, INM’s financial position was such that the Company was in a position to evaluate

acquisition opportunities. While INM has stated publicly its ambition to invest in and acquire digital

assets, INM has also reiterated on numerous occasions its belief in the print and publishing industry

in Ireland.

17. INM also believes that it has an obligation to the industry not just to direct investment abroad but to

use its resources to sustain and improve the existing newspaper offer in the island of Ireland and the

jobs that are necessary to create that.

Proposed acquisition of CMNL

18. The Proposed Transaction with CMNL, currently under review by the BAI, demonstrates this belief

in the Irish publishing industry in a tangible way. INM strongly believes that the Proposed

Transaction involving CMNL is beneficial to regional papers in general and CMNL in particular. This

acquisition will provide much needed financial support to CMNL, secure the future of CMNL’s seven

titles (two of which are free titles) and the associated jobs and give these titles the opportunity to

leverage INM’s resources, knowledge and scale to deliver a strong, more robust and more

sustainable CMNL for the future.

19. INM is currently developing a solution for local and regional papers to also be able to reach readers

through the digital channel and this will be available to CMNL newspapers making them more

attractive to readers and securing their long-term future.

SECTION 2 – CHALLENGES FACINGTHE IRISH NEWSPAPER INDUSTRY

Declining circulation and revenue

20. The newspaper publishing industry in Ireland, both local and national, has faced and continues to be

challenged by severe disruption. The factors causing this are:

A move by the consumer from consuming content in newspapers to digital.

Significantly lower yield from digital advertising than print advertising.

3 https://www.theguardian.com/media/2009/apr/30/independent-news-media-bondholders

5

A market where Irish publishers also face competition from foreign owned newspapers,

often with lower cover prices.

Severe impact from Ireland’s unprecedented economic crisis. Where large parts of the

economy have started to recover, the upturn has not impacted into the newspaper industry.

The industry is freshly hit by the UK’s Brexit vote with markedly worse performance in

advertising revenues since June 2016 and an uncertain outlook to the future.

21. As a result, the industry has seen the following, making the need for consolidation even more

important:

62% decline in print advertising revenues since 20074.

39% decline in circulation volumes since 20075.

Continuing programmes of redundancies across the industry, with the existence of several

titles now under threat.

Digital challenge

22. In an article entitled “Facebook is eating the world”, published in the Columbia Journalism Review in

March 2016, the author states that “our news ecosystem has changed more dramatically in the past

five years than perhaps any time in the past five hundred”6.

23. The challenges facing the industry are being exacerbated by the rise in news consumption via social

media platforms. According to Reuters Institute for the Study of Journalism - Digital News Report

2016, 45% of people in Ireland consume news via Facebook on a weekly basis7.

Newspaper closures

24. The financial challenges which have impacted the publishing industry have resulted in the closure of

many regional and national titles across Ireland.

4 ABC 5 NewsBrands Ireland (formerly NNI) 6 http://www.cjr.org/analysis/facebook_and_media.php 7 https://reutersinstitute.politics.ox.ac.uk/sites/default/files/Digital-News-Report-2016.pdf

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25. The pressures brought on by the recent economic crisis led to the closure by Alpha Newspapers of

three local newspaper titles (Roscommon Champion, Longford News, and Athlone Voice) in Ireland. At

the time, Minister Naughten was reported as saying:

“'the closure of the papers is devastating news for the 40 employees who will lose their jobs, but it is

also a major blow for the area” 8

Mr Naughten said all three papers had a history of fine reporting of local stories and events and it

was "sad news that these three titles have now joined the growing number of local newspapers being

forced to close their doors across the country"

“In particular the Roscommon Champion, which had incorporated the earlier titles the Roscommon

Messenger and the Roscommon Journal and Western Impartial Reporter, had a long history in

community life in the county and had been published for over 80 years."9

26. The UK, being the closest overseas market, has experienced similar pressures. Research by the Press

Gazette10 states that 198 local newspaper titles have closed since 2005, including 46 local

newspapers since 2015. These closures were offset somewhat by the launch of 29 new titles in

2015-16. The closures can primarily be attributed to the increasing financial pressure on

newspapers and the pressure to remain relevant and to attract new consumers.

27. Johnston Press, a UK publisher of local newspapers, closed 19 local newspapers in 2015/16. The

Company also undertook a review of its newspaper title portfolio in January 2016 identifying 59 as

“sub-core”, seven of which are located in Northern Ireland11.

SECTION 3 – CONSOLIDATION & COLLABORATION

28. In the face of a persistent decline in both circulation and advertising revenues, news organisations

have faced increasing pressure to remain commercially viable. As a result, consolidation and

collaboration has become commonplace in the global newspaper industry.

29. Consolidation and collaboration is occurring between publishers to enable the production and

distribution of newspapers in the most efficient manner possible. INM and the Irish Times, INM’s

primary competitor in the national market, have entered into mutually beneficial agreements

whereby The Irish Times print certain INM titles and Newspread (INM’s distribution business)

distributes the Irish Times. Such collaboration is a necessity to ensure publishers remain

competitive and INM expects consolidation and collaboration to become more commonplace in the

future. This protects media plurality by protecting the commercial operations of publishers.

30. Such measures are not unique to Ireland. In the UK, an automated booking system was created by

News UK, Mail Newspapers, Telegraph Media Group, Guardian Media Group and ESI Media in 2014

to simplify the transactions process between publishers and agencies12.

8 https://www.rte.ie/news/2010/0831/135039-alphanewspaper/ 9 http://www.irishtimes.com/news/three-midlands-newspapers-to-close-1.863348 10 http://www.pressgazette.co.uk/new-research-some-198-uk-local-newspapers-have-closed-since-2005/ 11 http://www.pressgazette.co.uk/johnston-press-identifies-59-sub-core-titles-including-wigan-evening-post-and-

scotland-sunday/ 12 http://www.thedrum.com/news/2014/07/02/news-uk-mail-newspapers-telegraph-guardian-and-esi-media-

fund-cross-industry

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31. Another possible UK collaboration reviewing the feasibility of pooling advertising sales resources

between News UK, Trinity Mirror, DMG Media, and Telegraph Media Group has recently faltered

following the withdrawal of DMG Media from the discussions13.

32. Taking into account the above, it is generally accepted that one of the lynchpins of a democratic

society is a free press which operates on an independent basis. It follows that, in order to establish

and maintain independence, media enterprises must be financially sustainable and capable of

survival in a commercial and competitive environment.

33. Consolidation across the newspaper industry has allowed publishers to use centralised back office

functions and infrastructure to produce newspapers of high quality despite falling revenues.

Consolidation is the only real means to ensure the continuation of many titles, the protection of jobs

and indeed the survival of newspapers which actually protects the diversity of views. The Proposed

Transaction will benefit CMNL by enabling access to the financial and operational resources of a

larger parent company, without any impact on editorial independence.

34. Some recent examples of consolidating acquisitions in the newspaper industry across the globe are

highlighted below:

Transaction Country Announcement Date Value Assets

News Corp acquired Australian

Regional Media from APN14

Australia June 2016 $37 million 12 daily and 60 community

titles

Gannett acquired Journal Media

Group15

USA October 2015 $280

million

33 titles (15 daily and 18

weekly)

Trinity Mirror acquired Local

World16

UK October 2015 £220

million

83 titles, including 16 daily

and 36 paid weekly titles

Post Media acquired Sun Media

from Quebecor17

Canada October 2014 $316

million

175 newspapers and digital

publications

SECTION 4 – NECESSITY FOR HEALTHY ROBUST INDUSTRY, AND INM’S CONTRIBUTION

Benefits of a strong newspaper industry

35. Newspapers have a strong tradition of delivering accurate, reliable news. This is especially

important amid concerns about “false news” and an “echo chamber” on social media which shield

people from diverse opinions.

36. The ongoing decline in newspaper circulation and revenue has created immense financial pressure

on publishers. Newspapers provide a vital role and deliver many benefits:

Newspapers provide journalistically researched professionally produced local news at

national and regional levels;

13 https://www.ft.com/content/8252e15c-dc0f-11e6-9d7c-be108f1c1dce 14 http://investorcentre.apn.com.au/phoenix.zhtml?c=144006&p=irol-news&nyo=1 15 http://investors.gannett.com/press-release/gannett-acquire-journal-media-group-1200-share 16 http://phx.corporate-ir.net/phoenix.zhtml?c=88476&p=irol-newsArticle_Print&ID=2103225&highlight= 17 http://www.postmedia.com/2014/10/06/postmedia-to-acquire-sun-medias-english-language-newspapers-and-digital-properties/

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The news provided by INM newspapers and CMNL newspapers is detailed and analytical and

contains diverse opinions;

Newspapers provide a significant social and economic benefit to society and are an important

conduit for the exercise of freedom of expression;

Newspapers act as a watchdog in society and are an essential component in our

representative democracy;

Newspapers provide employment to large numbers people through the entire value chain;

Newspapers provide advertisers with a means to connect with national and regional

audiences.

INM’s contribution to the newspaper market

37. Even as an industry facing challenges, as a result of INM’s strong belief in print, the company has

taken steps to ensure that the jobs it offers to those in the industry are of a quality that reflect the

demands and recognised accepted norms of Irish society in the 21st century. The Company has been

in position a to provide improved benefits to employees including:

Pay increases across the Group in 2016.

INM’s graduate recruitment programme is the only PA accredited editorial programme in the

country. This programme has an intensive academic element which was delivered by the

Press Association, London

In 2015, announced a €250,000 investment in a new Digital Training and Education

Programme, partnering with the National College of Ireland.

In 2015, introduced changes to the Company’s maternity and paternity policy providing 20

weeks paid maternity leave for mothers and 3 days paid paternity leave for

fathers/spouse/partner.

SECTION 5 – REGIONAL NEWSPAPERS

38. INM operate thirteen weekly regional newspapers including the Drogheda Independent, Wexford

People, The Kerryman and The Sligo Champion, which are published in counties Louth, Wexford,

Wicklow, Cork, Kerry, and Sligo. INM is also a member of Local Ireland (the industry group for

regional papers) and plays an active role in working with its peers on the questions facing the

channel.

Importance of local news to community

39. INM has a strong belief in the importance of local newspapers. Local newspapers deliver a number of

benefits to the communities they serve:

Local newspapers deliver local news for local people.

Social media platforms such as Facebook, which 45%18 of Irish people use weekly as a source

of news, cannot provide the journalistically researched professionally produced local news

and level of content provided by local newspapers which serve and inform their local

communities.

18 https://reutersinstitute.politics.ox.ac.uk/sites/default/files/Digital-News-Report-2016.pdf

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Every person in the community has an opportunity to hear the voice of their elected and

appointed officials speaking through their local newspaper.

Local newspapers are similar to public libraries and local museums in that they preserve

culture, educate and engage in order to build understanding on important issues that are

expensive or difficult to cover and are an important conduit for the exercise of freedom of

expression.

The reporters of local newspapers both inform and guard the public they serve and are an

essential component in our representative democracy.

Local newspapers provide employment to local communities. CMNL employ approximately 99

people in Meath, Cavan, Westmeath, Offaly and Mayo. A further c. 45 local people are also

employed in the print plant which produce CMNL’s newspapers.

The employment of local people in local communities’ produces a multiplier effect as the

wages earned by the employees of local newspapers are spent it the local community.

As regional newspapers are unique and particular to their geographic market, they are also a

very important part of retailers’ offer and generate footfall into locally owned businesses.

40. The importance of local newspapers was perhaps best summarised by An Taoiseach, reported in the

Sligo Weekender (24th to 28th October 2011) at the launch of Local Newspaper Week, an extract of

which is provided below:

“Week after week, our local papers provide a living commentary on towns and counties across Ireland

and what it means to live in them. Week after week, our people depend on their local newspapers to

provide an accurate perspective on issues of national interest. And every week they deliver; fulfilling the

responsibility of meeting the highest journalistic standards and breaking stories of public interest.

Anyone who has practiced politics in Ireland knows the important role played by local papers and the

unique trust and bond Irish communities have with their local papers.

With people in modern Ireland now living increasingly busy lives, the role played by our local press

must continue to be a vibrant one. Of course, the first duty of local papers is to inform the reader, both

on local and national stories, but they also do much more than that. In fact they (Local Newspapers)

are a vital part of the fabric of rural life, serving to cement our links to our communities and always

providing an insight into the bustling society of Ireland’s towns and villages”.19

IMN’s commitment to regional newspapers

41. INM is a fully committed publisher of regional newspapers in Ireland. Its stable of regional

newspapers includes iconic titles such as The Kerryman (first published in 1904), The Sligo

Champion (first published in 1836), Wexford People (first published in 1853). In total INM publishes

13 regional titles. INM is aware of the importance of our regional newspapers to the communities

they serve and takes its role as custodian of these titles very seriously.

Lack of overlap between INM and CMNL titles and existence of competing newspapers in every

area

42. Following an in-depth economic assessment of the affected markets, consideration of detailed

submissions from the parties involved, as well as consultations with competitors of the merging

parties and other third parties, the CCPC determined that although both INM Holdings and CMNL are

involved in publishing local/regional newspapers, that the Proposed Transaction “does not give rise

to horizontal overlaps in different local/regional areas for the publication of local/regional

19 https://issuu.com/datascope.ie/docs/sligo_week43web/43

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newspapers based on readership” except for minor spill-over sales20. The following map illustrates

the lack of overlap between INM’s regional newspapers and those of CMNL.

43. It is important to note that in each of the areas where CMNL currently operates there are competing

newspaper titles. For example, in Mayo where CMNL publishes The Connaught Telegraph there are

three other local newspapers, namely, the Mayo News, the Western People and the Mayo Advertiser.

In Offaly, where CMNL publishes the Offaly Independent, there are four other newspapers namely,

Offaly Express, Tullamore Tribune, Midland Tribune and Offaly Topic. In Meath, where CMNL

publishes Your Forum and Meath Chronicle, the Meath Herald is a competing title. In Cavan, where

CMNL publishes The Anglo Celt, there is the Northern Standard. In Westmeath where CMNL

publishes Westmeath Examiner and Westmeath Independent, there are three other newspapers,

Westmeath Topic, Athlone Advertiser and Athlone Topic.

Necessity of local content for local titles

44. INM regional newspapers use locally-based sources for its news, sports, current affairs and cultural

interest content. It is INM’s belief that for regional newspapers to be attractive to readers in each

local area they must address the needs of their communities and to be commercially viable, the

content must remain local.

Performing strongly but lagging national declines

45. There are no ABC numbers for regional newspapers, however, INM estimates that circulation

volume in this channel fell c.3% in 201621. While this performance is encouraging, it is INM’s belief

20 Determination of CCPC M16/044-INM/CMNL 10th November 2016, Paragraph 42

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that regional circulation volumes are lagging their national counterparts and it is expected to come

more broadly in line with national title declines. As that accelerates, it will be even more difficult for

regional papers to reorganise and companies such as CMNL will come under increasing pressure.

SECTION 6 – EDITORIAL INTEGRITY

CMNL titles under INM

46. Under INM ownership, CMNL’s titles will continue to produce news in the same manner as under the

current ownership. Editors of CMNL titles, along with regional editors in INM, will continue to have

full autonomy over the content of their newspapers following the Proposed Transaction. As a result,

CMNL’s newspapers will remain the same to consumers, indistinguishable from the newspaper

produced under the ownership of Celtic Media Group.

Existing editorial practices in INM

47. INM management has no operational involvement in the editorial functions of INM national and

regional newspapers.

48. The editors of INM newspapers have editorial independence and control over the integrity, tone and

content of their respective newspapers, whilst ensuring compliance with the rules and regulations of

the Press Council of Ireland. INM corporate management does not exercise any editorial oversight or

control. All editorial matters are reserved for the editorial function.

49. In particular, the editors of INM regional newspapers have independence in their decision making to

accurately reflect the views of their communities and chronicle the events and news in their areas.

50. The general editorial structure within INM is that the editor has an assistant editor/commissioning

editor with a number of sports editors, staff journalists and freelance journalists reporting to him or

her (numbers varying between INM newspapers). The editor has seniority within that structure in

that he or she has final “sign-off” on what content appears in each newspaper and where it is

positioned.

51. Each editor reports to INM management to the extent necessary for commercial management and

governance reasons. For example, each editor provides INM management with updates of expected

trends in circulation.

Regional reporting lines

52. Currently, INM has two Regional Managing Directors (responsible for INM’s East and West regional

newspaper operations respectively). These Regional Managing Directors do not and cannot

influence the editorial decisions of editors, who retain full autonomy over the content of their

newspapers.

53. There are separate reporting structures for INM regional newspapers which operate in isolation to

those for INM national newspapers. As noted above, INM regional editors report directly into the

Head of Regionals. Thus, the editors of INM regional newspapers do not report to editors of INM

national newspapers who have no input into the content produced in INM’s regional titles.

21 Internal data

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SECTION 7 – POSITIVE IMPLICATIONS OF THE PROPOSED TRANSACTION

Why the Proposed Transaction makes sense

54. CMNL has been experiencing cash flow difficulties due to significant investment in a new publishing

system and the funding of redundancies, allied to declining revenues. INM’s expertise and focus on

this area will enable CMNL newspapers to enhance their digital offering to attract new readers

(including key younger demographics) and additional revenue.

55. The long-term viability and quality of the CMNL newspapers could be at risk if the Proposed

Transaction does not go ahead. CMNL is mid-way though a major IT investment project and failure

to complete this project will have a negative impact on trading performance.

56. By providing financial support to CMNL, the Proposed Transaction will secure the future of CMNL’s

titles. It is important to note that the CMNL titles all face competition from other titles in their

respective areas so that there are a range of newspapers available to all readers. The Proposed

Transaction will also ensure high quality employment continues in the CMNL’s communities Meath,

Westmeath, Cavan, Offaly and Mayo.

57. By securing the future of CMNL’s titles, the Proposed Transaction will ensure that the distinctive

voice of CMNL newspapers will continue.

CCPC Determination

58. It is important to note that following a thorough review of INM and CMNL’s joint submission to the

CCPC, the CCPC determined that the acquisition of CMNL by INM would not lead to a substantial

lessening of competition.

59. The CCPC’s determination on 10th November 2016 stated:

“…The CCPC’s analysis involved in-depth economic assessment of the affected markets, consideration of

detailed submissions from the parties involved, as well as consultations with competitors of the merging

parties and other third parties, The CCPC concluded that, although both INM Holdings and CMNL are

involved in publishing local/regional newspapers, there is very limited overlap between their activities

and the transaction would not lead to a substantial lessening of competition...”22

CONCLUSION

60. Print publishing faces unprecedented challenges in today’s world, particularly on the island of

Ireland where the language, scale and geographical proximity to the UK mean that the offer to

readers and advertisers is extremely wide. That is further exacerbated by the move to digital where

the lack of a clear roadmap and the shrinking in yield on revenue lines is destroying value.

61. For companies, such as CMNL, the future is very uncertain unless they can find a way to ease the

burden as a result of those challenges. With so much uncertainty created by digital, economic

uncertainty and now also Brexit (many of CMNL’s titles are near the border with Northern Ireland

and cross border shopping is impacting retailers in their markets) it is imperative that CMNL

achieves security for it future and the jobs of its employees. INM offers the opportunity of that safety.

22 CCPC M16/044-INM/CMNL Merger Announcement 10th November 2016

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62. There are no geographic overlaps between any of INM’s current regional papers and those of CMNL.

Every market in which CMNL operates has alternative publications which offer different voices to

the reader. INM is committing to maintain each paper’s presence in these markets.

63. The CCPC recognised this fact when they determined that the transaction would not lead to a

substantial lessening of competition in any market for goods or services in the State and the

transaction could be put into effect subject to the provisions of 28C(1) of the Competition Acts 2002-

2014.

64. Readers of CMNL will still continue to enjoy a relevant, well-produced and accurate newspaper,

continuing the proud history of these newspapers and the excellent work of current management

(who are staying with the business and joining INM). They will also have reassurance that their

future right to be informed, educated and challenged about their local community will be protected

by CMNL joining INM. The opportunity for their children to have that same right but on a digital

platform will also be enhanced.

65. Employees of CMNL will benefit from the greater security offered as part of the INM group. That

there is no geographic overlap means that they continue in their roles knowing that what they

produce is unique within INM. The quality of those jobs will also be protected and their access to

training, development and maternity care enhanced.

66. Lastly, the actual titles of CMNL are the most important matters at stake here. Those titles are:

The Connaught Telegraph

Offaly Independent

Your Forum (Meath)

Meath Chronicle

The Anglo Celt

Westmeath Examiner

Westmeath Independent

67. INM believes in regional publishing, as it does in print publishing in Ireland. It will invest in and

protect these newspapers and in so doing transform a very uncertain future for CMNL into one

where it has much better prospects, benefitting all stakeholders.

ENDS