Pro​Global​Networks Telemarketing Compliance Policy

1. Written Telemarketing Compliance Policy

Pro​Global​Networks ("Company") maintains a comprehensive written telemarketing policy to ensure full compliance with all applicable federal and state telemarketing laws and regulations, including:

• Telephone Consumer Protection Act (TCPA) - 47 U.S.C. § 227
• Telemarketing Sales Rule (TSR) - 16 CFR Part 310
• CAN-SPAM Act - 15 U.S.C. § 7701
• State telemarketing laws and regulations in all jurisdictions where we operate

Core Compliance Requirements

Express Written Consent: All telemarketing calls to cell phones require prior express written consent before using automated dialing systems or prerecorded messages.

Calling Time Restrictions: Telemarketing calls are conducted only between 8:00 AM and 9:00 PM in the prospect's local time zone.

Caller Identification: All outbound calls display accurate caller identification information including company name and valid callback number.

Call Recording Disclosure: When calls are recorded for quality assurance, proper disclosure is provided at the beginning of each call.

Lead Freshness: Leads are contacted within regulatory timeframes and industry best practices for lead age requirements.

2. Do Not Call (DNC) Policy

National Do Not Call Registry Subscription

Answer: YES

Pro​Global​Networks subscribes to and regularly scrubs all leads against the National Do Not Call Registry maintained by the Federal Trade Commission. We update our suppression lists monthly and conduct additional scrubbing before each campaign launch.

State Do Not Call Registry Subscription

Answer: YES

Pro​Global​Networks subscribes to and maintains current suppression lists for all applicable state-specific Do Not Call registries in every state where we conduct business operations.

Consumer DNC Request Compliance

Answer: YES

Pro​Global​Networks honors all consumer requests to be placed on our company-specific Do Not Call list as mandated by federal and state laws. Our process includes:

• Immediate cessation of contact upon consumer request
• Addition to internal suppression list within 24 hours
• Written confirmation of DNC status to consumer when requested
• Distribution of updated DNC list to all agents and partners

DNC List Maintenance

Answer: YES

Pro​Global​Networks maintains consumers on our internal Do Not Call list permanently unless one of the following limited exceptions applies:

• Consumer provides explicit written consent to remove their number from our DNC list
• Phone number has been disconnected and reassigned to a different person (verified through telecommunications carrier records)
• A legitimate established business relationship exception applies under TCPA regulations

3. DNC Compliance Procedures

Lead Processing

1. Pre-Campaign Scrubbing: All leads are scrubbed against National and State DNC registries before distribution to agents or partners
2. Real-Time Verification: Our call routing system includes real-time DNC checking capabilities
3. Suppression Integration: Internal DNC lists are integrated with all dialing and lead management systems

Agent and Partner Requirements

1. Training: All personnel receive initial and ongoing training on DNC compliance requirements
2. Documentation: All DNC requests are logged with timestamp, agent identification, and method of request
3. Partner Compliance: All lead generation partners must maintain equivalent DNC policies and provide compliance certifications

Record Keeping

1. Audit Trail: Complete records of all DNC activities maintained for minimum five (5) years per regulatory requirements
2. Registry Updates: Documentation of all National and State DNC registry update activities
3. Consumer Requests: Detailed logs of all consumer DNC requests and company responses

4. Compliance Monitoring and Enforcement

Oversight Structure

Compliance Officer: Designated compliance officer responsible for oversight of all telemarketing compliance activities

Regular Audits: Monthly internal audits of DNC compliance procedures and quarterly comprehensive compliance reviews

Violation Response: Immediate investigation and remediation protocols for any identified compliance violations

Policy Updates

This policy is reviewed annually or upon changes to applicable federal or state regulations. All employees, contractors, and business partners are notified of policy updates within 30 days of implementation.

5. Contact Information

For questions regarding this Telemarketing Compliance Policy or to make a Do Not Call request, please contact:

Pro​Global​Networks Compliance Department
Email: pro​global​networks​@fast​mail​.com
Address: Pro​Global​Networks L​L​C, 30​ N ​Gould​ St, Sheri​dan​ W​Y​ 82801

Policy Effective Date: February 13, 2026

This policy is binding on all employees, contractors, and business partners involved in telemarketing activities conducted on behalf of Pro​Global​Networks.