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Telemarketing and "Blast" Emailing/Faxing Policy

All telemarketing scripts must comply with this Policy and applicable federal and state rules and regulations. Before implementation of any telephonic campaign, the Company must confirm that telephone numbers are scrubbed against the National Do Not Call list and any applicable state-specific Do Not Call lists.

Employees may NOT PERFORM ANY random telemarketing or unsolicited faxes/emails. No exceptions to this rule! AFN, however, may approve legally purchased Do-Not-Call (DNC) list scrubbed leads for solicitation from reputable marketing companies. Requests for approval must be submitted to the marketing department for legal review.

The Federal government and most states regulate telemarketing. Collectively, the Federal Trade Commission, Federal Communications Commission, State Regulations, States Attorney Generals, Public Utilities Commissions and Public Services Commissions HEAVILY regulate Telemarketing and Unsolicited Faxing/Emailing (CA maintains 25 separate state, county, and city consumer protection agencies with various rules). The Telephone and Consumer Fraud Abuse Prevention Act and Telephone Consumer Protection Act (TCPA) permit sanctions, including disconnection of the utilities, $500 per wrongful contact or $1,500 per knowing, wrongful contact, and possibly more if consumers prove damages.

NO Prerecorded Messages or Auto-Dialers without Live Voice Introduction: Recently, the TCPA required companies to conform to the new FTC rules, including that a telemarketer cannot place calls to residences absent “express consent” for such calls. Certain states, for example – California, require that a live voice must provide the name, address, and telephone number of the business, and then ask permission to play the pre-recorded message.

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