Do Not Call Policy

Etech Global Services, LLC and its affiliates ("Etech," "we," "us") operate outbound voice, SMS, and multi-channel programs on behalf of clients across telecommunications, insurance, financial services, healthcare, automotive, retail, education, and other regulated industries. This Do Not Call Policy ("Policy") sets out the rules Etech follows to comply with the United States Telephone Consumer Protection Act ("TCPA"), the Federal Trade Commission Telemarketing Sales Rule ("TSR"), the Federal Communications Commission rules implementing the TCPA, state mini-TCPA statutes, and equivalent Canadian and other non-U.S. telemarketing rules where Etech delivers service.

Etech maintains a telemarketing compliance program designed to align with the TCPA, the Telemarketing Sales Rule, and applicable state law. The controls described in this Policy represent the minimum standard applied across every outbound program Etech runs, regardless of client instruction. Compliance records are available for client review under NDA.

This Policy describes Etech's own telemarketing posture on www.etechgs.com and Etech's general operating standard when we act as a service provider for client outbound programs. Two layers apply:

• Controller layer. When Etech calls, texts, or emails a person for Etech's own sales or marketing purposes, Etech is the controller. Etech scrubs, trains, records, and retains consent records for those contacts directly.
• Processor layer. When Etech dials on behalf of a client under a Master Services Agreement and Data Processing Addendum, the client is the controller of the calling list and the legal basis for contact. Etech operates as a service provider and applies the client's instructions, adds Etech's own compliance overlay, and will refuse instructions that place Etech out of compliance with the TCPA, the TSR, or state law.

Etech's outbound operation is built against the following United States federal and state frameworks. Canadian, United Kingdom, Australian, and EU equivalents are applied for programs dialing into those jurisdictions.

• Telephone Consumer Protection Act of 1991 (47 U.S.C. § 227) and implementing Federal Communications Commission rules at 47 C.F.R. § 64.1200.
• Telemarketing Sales Rule at 16 C.F.R. § 310, as amended, including the 2024 amendments extending coverage to inbound technical-support calls.
• Federal Trade Commission Do Not Call Implementation Act and the National Do Not Call Registry operated by the Federal Trade Commission.
• State mini-TCPA statutes including the Florida Telephone Solicitation Act (FTSA), Oklahoma Telephone Solicitation Act (OTSA), Washington Commercial Electronic Mail Act, New York General Business Law § 399-p, and similar statutes in Texas, Indiana, Louisiana, Maryland, Missouri, New Jersey, and Tennessee.
• Canadian Radio-television and Telecommunications Commission Unsolicited Telecommunications Rules and the National Do Not Call List for programs dialing into Canada.
• Privacy and Electronic Communications Regulations 2003 (UK) and the Telephone Preference Service for programs dialing into the United Kingdom.
• Applicable state insurance licensing, state dealer franchise rules, and healthcare telephonic outreach rules as program type requires.

Etech maintains an active subscription to the National Do Not Call Registry operated by the Federal Trade Commission. Every outbound calling list used for solicitation is scrubbed against the National Registry on the following cadence:

• Full list scrub no more than 31 calendar days before the first dial of any campaign, consistent with 16 C.F.R. § 310.4(b)(3)(iv) and 47 C.F.R. § 64.1200(c).
• Ongoing rescrub at least every 31 days for any campaign that runs continuously.
• Pre-dial check against the latest National Registry download for long-running list-based campaigns where the list is refreshed between scrubs.
• Area-code-level downloads only for the states in which the campaign dials, to minimize data exposure.

Registry subscription records, download timestamps, and scrub logs are retained for five years, consistent with TSR recordkeeping rules at 16 C.F.R. § 310.5.

For states that maintain their own Do Not Call list separate from the National Registry or that impose tighter rules than federal law, Etech scrubs against the state list in addition to the National Registry. At minimum, state lists are handled as follows:

Etech maintains a company-wide internal Do Not Call list. The internal list aggregates every number for which a person has asked not to be called, across Etech's own programs and every client outbound program Etech runs, subject to the two-layer model in Section 02.

• Any request to stop calling, whether made to an agent, a supervisor, a regulator, or through the opt-out URL on a written opt-in asset, is added to the internal Do Not Call list within 5 business days and honored across every Etech-run program from that point forward. For client-managed programs, opt-outs are also transmitted to the client suppression system on the next scheduled data exchange, not to exceed 10 business days.
• The internal DNC list is honored for five years from the date of the request, consistent with the TSR.
• On client programs, the opt-out is logged to both the Etech internal DNC list and, where the client requires, the client's own suppression list via the Data Processing Addendum return-path.
• The internal DNC list is searchable by phone number, by email, and by third-party identifier where a client dials against a consumer identity graph.

Calling a wireless number using an automatic telephone dialing system or an artificial or prerecorded voice without prior express written consent is prohibited by the TCPA. Etech's outbound stack implements the following controls:

• Every outbound calling list is screened against a wireless identifier database before dialing.
• Etech queries the Reassigned Numbers Database operated by Somos, Inc. for consent-based calls to protect the safe-harbor defense under 47 C.F.R. § 64.1200(a)(4).
• Calls to numbers identified as wireless or reassigned are routed through the consent-verification gate before connection.
• Prerecorded voice messages are only delivered to wireless numbers with documented prior express written consent.

For calls that require prior express written consent under the TCPA, Etech will only dial against a consent record that contains:

• The consumer's signature, which may be an electronic signature under the Electronic Signatures in Global and National Commerce Act.
• Clear and conspicuous disclosure that the consumer is authorizing the seller to deliver or cause to be delivered telemarketing calls or text messages using an automatic telephone dialing system or an artificial or prerecorded voice.
• The telephone number to which the authorization applies.
• A disclosure that the consumer is not required to provide consent as a condition of purchase.
• The date of consent, source asset, and a durable record of the consent screen or form.

A consumer may revoke prior express written consent at any time, through any reasonable means. Etech honors revocation through every channel on which it is received:

• Verbal request to any Etech agent during any inbound or outbound call on any line Etech operates.
• Response keywords on SMS programs including STOP, UNSUBSCRIBE, QUIT, END, CANCEL, REVOKE, and OPT OUT.
• Email to Privacy@etechgs.com or to the email address printed on the opt-in asset.
• Written request to 1903 Berry Drive, Nacogdoches, Texas 75964.
• Any channel that a reasonable person would use to communicate the revocation, consistent with the FCC 2024 Order on consumer consent revocation.

Revocation is logged, suppressed across channels within 24 hours where operationally possible and in no case later than 10 business days as required by the FCC, and retained for five years.

Outbound telemarketing calls are placed only between 8:00 a.m. and 9:00 p.m. in the recipient's local time, consistent with 16 C.F.R. § 310.4(c) and 47 C.F.R. § 64.1200(c)(1). State law is applied where tighter.

• The dialer resolves recipient local time from the area code and billing ZIP code on the consent record, not from the agent's time zone.
• Recipient-initiated callback requests are honored as stated on the call. A recipient-requested window overrides the default 8:00 a.m. floor or 9:00 p.m. ceiling only if the recipient requested it in writing or on a recorded line.
• Frequency caps are enforced per program. Etech's default cap is no more than 3 attempts per 24-hour period and no more than 7 attempts per 7-day period for any number that has not connected, subject to state law.
• Programs dialing into Sunday or recognized state and federal holidays require pre-approval and are paused by default for consumer programs.

Etech operates predictive and progressive dialers under the following abandoned-call controls:

• Abandoned call rate below 3% of answered calls, measured per campaign over each successive 30-day period, consistent with the TSR safe harbor at 16 C.F.R. § 310.4(b)(4).
• A whisper message identifying the seller and the purpose of the call is played on every abandoned connection within 2 seconds of the connection, as required by the safe harbor.
• Ring-no-answer timing of at least 15 seconds, or 4 rings, before the call is abandoned.
• Agent-to-line ratio and pacing algorithms are monitored in real time by workforce management and QEval. Any campaign exceeding the 3% cap is automatically throttled.
• Full dialer event logs including pacing, abandon rate, whisper delivery, and agent availability are retained for 5 years.

All outbound calls transmit an accurate caller identification number that, when dialed, reaches the seller or Etech on behalf of the seller. Within the first 60 seconds of every outbound telemarketing call, the Etech agent identifies:

• The agent's name or a consistent agent identifier.
• The seller on whose behalf the call is being made.
• The purpose of the call.
• If applicable, that the purpose of the call is to sell goods or services.

Caller ID spoofing is prohibited by the Truth in Caller ID Act, 47 U.S.C. § 227(e). Etech does not spoof caller ID and does not accept client instructions that would require caller ID spoofing, to the extent permitted by applicable law. Etech dials from numbers attested under STIR/SHAKEN at A-level attestation through carrier partners.

Every outbound telemarketing call Etech places is recorded for quality, training, and compliance purposes. The standard recording disclosure is delivered on every call. Where the recipient is located in a two-party consent jurisdiction including California, Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Oregon, Pennsylvania, Vermont, and Washington, the disclosure is delivered before any substantive conversation occurs and the call is dropped if the recipient objects.

Certain categories of calls are exempt from DNC scrubbing under 16 C.F.R. § 310.4(b)(1)(iii) and 47 C.F.R. § 64.1200(f)(5). Etech applies exemptions narrowly and always documents the exemption basis in the campaign record:

• Calls to a person with whom the seller has an established business relationship within the relevant TSR window (18 months from the last transaction, 3 months from the last inquiry or application).
• Calls made at the express invitation of the consumer.
• Calls made for a purely informational purpose with no solicitation content (for example, appointment reminders, shipment updates, account security alerts).
• Calls on behalf of tax-exempt nonprofit organizations to the extent the federal and state regimes permit.
• Calls made solely to collect a debt owed by the consumer, subject to the Fair Debt Collection Practices Act.

Every Etech agent who handles outbound calls completes TCPA and TSR training during the Etech hiring and onboarding sequence, and refresher training at least annually. State-specific content is added for licensed programs. Training is delivered by the Etech Learning and Development team under Melissa Wood.

• QEval speech analytics is deployed across Etech-managed outbound programs, targeting full-coverage analysis of answered calls for scripted disclosure delivery, opt-out handling, calling-hour compliance, and caller identification. Coverage metrics are reported to clients monthly and exceptions are documented in the QEval program dashboard.
• Agent-level scorecards measure DNC and TCPA compliance as a dedicated scorecard category. Any compliance score below threshold triggers immediate coaching and call review.
• Compliance exceptions are reported to the Etech Compliance Committee weekly. Material exceptions are reported to the client within 24 hours under the applicable Data Processing Addendum.
• Etech retains documented call monitoring and training records for a minimum of 24 months and for 5 years on records supporting TSR safe-harbor claims.

Any consumer may submit a DNC or TCPA complaint to Etech by any of the channels listed below. Etech acknowledges receipt within 2 business days and aims to complete the investigation within 30 calendar days, or sooner where state law requires. Complex matters requiring multi-party coordination may require additional time; the consumer will be notified of any extension.

• Email: Privacy@etechgs.com
• Mail: Privacy Office, Etech Global Services, LLC, 1903 Berry Drive, Nacogdoches, Texas 75964
• Phone: +1 (936) 559-2200

Consumers retain the right to file a complaint directly with the Federal Trade Commission at donotcall.gov, the Federal Communications Commission at fcc.gov/consumers/guides/stop-unwanted-robocalls-and-texts, their state Attorney General, or, if the consumer is in a European Economic Area member state, the United Kingdom, or Canada, the applicable national regulator.

Accountability for this Policy is held by the Etech Chief Compliance Officer, in coordination with the Information Security Officer and the Legal department. The following records are retained to support this Policy:

• National DNC Registry subscription identifier and download logs: 5 years.
• State DNC subscription records and download logs: 5 years.
• Campaign-level scrub records linking a list to a specific download date and registry version: 5 years.
• Prior express written consent records: duration of the consent plus 5 years after revocation.
• Call recordings and QEval analytics outputs: default 24 months, extended per client Data Processing Addendum.
• Internal DNC list entries: 5 years from the date of the opt-out.
• Compliance training attendance and assessment results: 3 years.
• Compliance Committee minutes and exception reports: 5 years.

Etech reviews this Policy at least annually and revises it following any material regulatory change. The effective date at the top of this page is updated on every revision. Material revisions are communicated to clients under the notice provisions of the Master Services Agreement or Data Processing Addendum in force.

For questions about this Policy or for any DNC request, contact: