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Do Not Call Policy

PURPOSE OF “DO NOT CALL” POLICIES AND PROCEDURES:

Federal law requires each company, with the exception of those making nonprofit solicitations, to maintain a list of those people who do not wish to be contacted by phone and to develop a written policy implementing this “do not call” list-keeping requirement. These written procedures are required to be available to anyone on demand and must include the following:

1. HOW CUSTOMER SERVICE REPRESENTATIVES (CSRs) AND TELEMARKETING SALES REPRESENTATIVES (TSRs) CAPTURE “DO NOT CALL” REQUESTS

CSRs receive “do not call” requests from inbound calls and letters from people who do not wish to be contacted by phone and input this information on a Do Not Call web interface. This information is uploaded to the main no call list at the end of each shift. TSRs receive “do not call” requests directly from people in the course of their outbound telemarketing sales solicitations, inbound calls and from letters sent directly to one of several departments or to management representatives within the company. These requests are also input on a Do Not Call web interface and uploaded to the main no call list at the end of each shift.

2. METHOD AND SPEED WITH WHICH INFORMATION IS ENTERED INTO THE SYSTEM

Upon receiving a Do Not Call request, the TSR or CSR personally enters the “do not call” information directly into a database through a web interface. This database is uploaded at the end of every shift to the outbound solicitation system. This information is permanently stored in a “do not call” filter within the outbound solicitation system within 24 hours of when the request was made. Telemarketing supervisors conduct periodic audits to ensure that requests are entered in a timely and accurate manner.

3. MANNER AND TIMELINESS OF PROVIDING “DO NOT CALL” POLICIES AND PROCEDURES WHEN REQUESTED

The Telemarketing Department will send a copy of the “Do not call” policies and procedures to whoever requests this information within 24 hours of having received appropriate notice from within Telemarketing or from other individuals or departments within the company receiving such a request. Confirmation is sent to individuals or departments outside of Telemarketing notifying them that a copy of the “Do not call” policies and procedures policies and procedures were sent as requested.

4. HOW THE ACCURACY AND INTEGRITY OF THE DATABASE IS MAINTAINED

When “do not call” information is entered into “do not call” filters in the outbound solicitation system, the filters become a permanent part of the operating protocol of the system. Each day, prior to activation the system, electronic sensors scan the calling numbers and delete any phone numbers that appear in the “do not call” filters and flags. These filters and flags must be in place before activating the system. Following the electronic scan, a system supervisor personally ensures that all filters are in place before activation the system
“Do not call” lists are not sold, or in any way shared (except with a subsidiary or affiliate company), without the consumer’s consent.