DO NOT CALL POLICY AND PROCEDURE
It is the policy of the company to fully comply with all applicable “Do Not Call” laws and regulations regarding wired and wireless telephone communications (whether by live, artificial or prerecorded voice, telephone facsimile machine, computer or otherwise) to any covered telephone line or number. In a good faith effort to so comply and to provide consumers with an opportunity to exercise their “do not call” rights, the Firm hereby establishes, and will implement, the following procedures:
(1) No representative of the Firm shall initiate any telephone solicitation, as defined by law, to any residential telephone subscriber before the hour of 8:00 a.m. or after 9:00 p.m. (local time at the called party=s location).
(2) The Firm shall maintain a “company specific” do not call list and shall promptly honor a request to be placed on the company do not call list immediately. In the Five 9 dialing system there is an option to disposition the client as DNC (Do Not Call). Once that client is dispositioned accordingly the system automatically removes the client and will never dial that client again.
(3) The company will also maintain a list of all clients requested to not be contacted again. Each entry on such “company specific” do not call list shall be retained for at least five (5) years or until the requester makes a further written request to be deleted from said list. The Company specific do not call list shall be readily available to all employees in the office.
(4) In order to comply with all applicable do not call laws and the Firm’s license law duty to supervise affiliated licensees, each representative of the Firm shall undergo periodic training-every three months-as to the applicable law regarding telephone solicitations, including a review of the applicable rules regarding do not call restrictions, and shall be subject to discipline, up to and including termination, for any failure to participate in such training and any failure to comply with the Firm’s Do Not Call Policy and Procedures, as well as all applicable legal provisions.
(5) In the event of any question regarding the provisions of applicable law or this Do Not Call Policy and Procedure, the representative of the Firm shall promptly contact office management to obtain clarification
HHDS Capital Investments, LLC
Do-Not-Call Checklist
HHDS Capital Investments, LLC has adopted and adheres to the policies described below to comply with the Federal Trade Commission’s (“FTC”) and Federal Communications Commission’s (“FCC”) regulations, The Direct Marketing Association’s (“DMA”) Ethical Guidelines, and if applicable, state Do Not Call laws.
HHDS Capital Investments, LLC checks telephone numbers on our calling lists against the DNC lists that we obtain from various sources, or we document why that person may be contacted without checking the DNC lists.
We honor the relevant portions of the national DNC list:
_X_ (a) each month
__ _ (b) each quarter, ____________ (indicate which months)
_ __ (c) other, please specify (cannot be less frequently than each quarter): ______________.
NOTE: Effective January 1, 2005 marketers will have to scrub against the national DNC every 31 days.
We check against the DMA’s Telephone Preference Service (“TPS”):
_X_ (a) each month
__ _ (b) each quarter, ____________ (indicate which months)
_ __ (c) other, please specify (cannot be less frequently than each quarter): ______________.
And, we check against state lists:
_ _ (a) each month
__ _ (b) each quarter, ____________ (indicate which months)
_X_ (c) consistent with state-mandated timetables.
_ __ (c) other, please specify: ______________.
In addition, to remove wireless numbers from our database we use:
___ (a) The DMA’s Wireless Suppression Service
___ (b) other, please specify; _____________________________.
We will also remove from our calling lists the telephone numbers of those individuals who submit requests directly to us. Consumers may submit DNC requests by (select all that apply):
_ __ (a) calling the following number: _______________, ext. ____
_ __ (b) writing to the following address: ____________________
_X_ (c) sending an e-mail to the following address: DNCrequest@hhdsllc.com.
_ __ (d) submitting a request online at the following URL:_____________________
__ _ (e) faxing a request to the following number: __________________________
_ __ (f) other: _______________________________________________________.
Such requests are recorded in our databases (select only one):
_ __ (a) within 24 hours of receipt
_X_ (b) within three business days of receipt
_ __ (c) within five business days of receipt
_ __ (d) other (please fill in appropriate response):___________________________,
NOTE: Federal regulations require companies to honor DNC requests within 30 days.
To fully implement such requests it may take up to:
_X_ (a) 30 days
_ __ (b) other (please fill-in appropriate response, but it cannot exceed 30 days.)
We retain company-specific DNC requests for a minimum of 5 years. If you move or change your telephone number your request may be deleted. If you wish to re-establish your Do-Not-Call request, please contact us at: _DNCrequest@hhdsllc.com.
We have trained our employees that are engaged in telephone marketing on these policies and procedures and we require our employees to follow them at all times. We have a policy of disciplining and we will discipline any employee who fails to abide by these policies and procedures.
If you have questions about our Do-Not-Call Policy, please contact us during normal business hours. Questions about our company’s DNC policies should be directed to DNCrequest@hhdsllc.com.