Telemarketing Compliance Policy

Purpose: This policy outlines our commitment to complying with all applicable telemarketing laws, including, without limitation, the Telephone Consumer Protection Act (TCPA), the Telemarketing Sales Rule (TSR), and similar state laws. The objective is to ensure our telemarketing practices respect consumer rights and adhere to legal requirements to avoid penalties and maintain our company's integrity.

Scope: This policy applies to all employees, contractors, and third-party vendors involved in telemarketing activities on behalf of our company.

Policy:

1. Compliance with Laws and Regulations:

   • All telemarketing activities must comply with the TCPA, TSR, and any relevant state laws.

   • Employees must stay updated on changes to these laws and regulations through regular training and updates provided by the company.

2. Do Not Call (DNC) Registry:

   • We must maintain and regularly update an internal Do Not Call list.

   • Telemarketing calls must not be made to numbers listed on the National Do Not Call Registry, the company's internal DNC list, or any relevant state-specific DNC lists unless an established business relationship exists or explicit prior consent has been obtained.

   • Our company must synchronize its DNC list with the National Do Not Call Registry at least once every 31 days.

3. Calling Times:

   • Telemarketing calls are only permitted between 8 a.m. and 9 p.m. local time of the recipient, as mandated by law.

   • Any deviations from these timeframes require explicit prior consent from the consumer.

4. Caller Identification:

   • Telemarketers must provide their name, the company’s name, and a contact phone number or address where the company can be reached.

   • Caller ID information must be accurately transmitted, including the name of the telemarketing company and a valid return phone number.

5. Consent and Opt-Out:

   • Obtain express written consent before making any automated, prerecorded, or artificial voice calls.

   • Provide a clear and easy-to-use opt-out mechanism during every call, allowing recipients to be added to our DNC list immediately.

6. Record Keeping:

   • Maintain records of all telemarketing activities, including consent records, call logs, and DNC list updates, for at least five years.

   • Keep records of all consumer complaints and the actions taken to resolve them.

7. Third-Party Vendors:

   • Ensure all third-party vendors comply with this policy and applicable telemarketing laws.

   • Conduct regular audits and assessments of third-party vendors to ensure compliance.

8. Training and Awareness:

   • Provide regular training to all employees and third-party vendors involved in telemarketing on legal requirements, this policy, and best practices.

   • Ensure new hires receive telemarketing compliance training before engaging in telemarketing activities.

9. Monitoring and Enforcement:

   • Implement regular monitoring of telemarketing activities to ensure compliance with this policy and applicable laws.

   • Take immediate corrective action in response to any non-compliance, which may include additional training, disciplinary action, or termination of third-party vendor contracts.

Policy Review: This policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, and company practices.

Acknowledgment: All employees and third-party vendors involved in telemarketing must acknowledge receipt and understanding of this policy.

By adhering to this policy, our company commits to conducting telemarketing activities ethically and legally, respecting consumer rights, and maintaining high standards of business conduct.

Effective Date: May 1, 2024

Authorized By: Adam Greenstein, CEO.