Safelink Field Agent Compliance Manual

Safelink Field Agent Compliance Manual

Who is TracFone? TracFone Wireless is America's largest No-Contract cellular service provider in the U.S. with over 25 million subscribers. It provides prepaid mobile phone service in the United States, Puerto Rico, and the Virgin Islands. TracFone Wireless is a subsidiary of América Móvil, the 5th largest cell phone company in the world and the largest in all of the Americas with more than 236 million wireless subscribers. What is LifeLine? Lifeline is a telephone assistance program. It is part of the Low Income Program of the Universal Service Fund. The Low Income Program, which is administered by the Universal Service Administrative Company (USAC), is designed to ensure that quality telecommunications services are available to low income customers at just, reasonable and affordable rates. Lifeline support reduces eligible consumers' monthly charges for basic telephone service and in the case of SafeLink allows us to provide a free cellular phone. Lifeline is a Federal supported service. Enrolling customers without proof or against their will is illegal and can and will be persecuted to the highest extent of the laws. What is Safelink? Safelink is Tracfone s brand through which Lifeline discounts are provided. Safelink offers free cell phone service for low income people all around the U.S., making sure that all Lifeline applicants qualify for the service. Role of Field Agents Field Agents are a group of qualified agents that help complete applications on the field for potential SafeLink customers. Field agents are employed by 3rd party marketing agencies. Qualified agents are provided by the third party marketing agencies with approved mobile devices to create Safelink applications and upload proofs, if applicable. They can also check the status of customers applications and some other related tasks.

Lifeline is a Federal Program Safelink Wireless provides qualified customers a free cell phone and free monthly minutes and texts. In California the offer varies. The amount of minutes and texts can change according to local, federal or competitive pressures. Only qualified customers can receive Lifeline support. Any agent(s) that tries to/helps/enrolls individuals who are not qualified will be suspended and at the worst prosecuted by the law. Safelink Wireless Program TracFone offers Lifeline services in states where it has been designated as an ETC (Eligible Telecommunications Carrier). Safelink Wireless is currently available in: Alabama (AL) Arizona (AZ) Arkansas (AR) Connecticut (CT) California (CA) D. of Columbia (DC) Delaware (DE) Florida (FL) Georgia (GA) Hawaii (HI) Illinois (IL) Indiana (IN) Iowa (IA) Kansas (KS) Kentucky (KY) Louisiana (LA) Maine (ME) Maryland (MD) Massachusetts (MA) Michigan (MI) Minnesota (MN) Mississippi (MS) Missouri (MO) Nevada (NV) New Hampshire (NH) New Jersey (NJ) New Mexico (NM) New York (NY) North Carolina (NC) Ohio (OH) Oregon (OR) Pennsylvania (PA) Puerto Rico (PR) Rhode Island (RI) South Carolina (SC) Tennessee (TN) Texas (TX) Utah (UT) Virginia (VA) Washington (WA) West Virginia (WV) Wisconsin (WI)

Qualification Criteria People must be qualified to receive Lifeline support. People are qualified for Safelink Wireless service (or any other Lifeline service) when they 1) participate in certain government assistance programs, or 2) meet the income qualification criteria. Program Qualification o Medicaid o Food Stamps o Temporary Assistance to Needy Families (TANF) o Supplemental Security Income (SSI) o National School Lunch Program (NSL) o Low Income Home Energy Assistance (LIHEAP) o Federal Public Housing/Section 8 o State program specified on the application form Note: Programs not listed on the SafeLink application form are NOT ELIGIBLE. Medicare, Social Security, and veterans benefits. This includes Note: In almost every state, proof of program participation will be required, and must be uploaded with their completed application. In some states customer eligibility may be verified through a database system. Program Qualification The following are some examples of what are considered valid proofs: - Copy of Food Stamps benefits letter - Copy of Medicaid card - Letter from Social Security Administration (SSA) stating that the applicant is currently receiving the selected government program. The letter must be current. - For Federal Public Housing or Section 8, a copy of the lease contract or a copy of the letter/document from the state agency, Local Housing Authority and/or the Housing Compound stating that customer receives or is approved for FPH. Note: Any card that does not show the customer's full name printed in the front or back, but has the customer's signature, must be submitted with any other valid document showing the customer's full name and signature (State ID Card, SSN Card, etc.)

Income Qualification Customers may also qualify via income. The qualifying income limit varies by state. The current income qualification levels will be provided on the customer application. Generally it is 135% of the Federal Poverty Guidelines. Note: Bank statements, checks and/or currency are not valid income proofs. Only the following will be considered as valid income proofs: - Last 3 months consecutive paystubs - Last year income tax return form - Last year W2 form - Letter from the SSA stating the benefits customer receives per month. Letter cannot be older than 12 months - In Florida, customers will not have the need to submit proofs because the OPC (Office of Public Counsel) will be the entity determining if the customer is eligible or not. It may take up to 2 weeks to validate the customer's information in Florida. - IRS Form

One Per Household Rule (OPHR) The Safelink Wireless service (as any other Lifeline service) is supported by the FCC and only one phone supported service per household is allowed. If a customer, or another member of the customer s household, already has a landline or cell phone with Lifeline discounts on it, they will not be able to get another Lifeline benefit. Note: Customers can have other cell phones or landlines, but they must not have any Lifeline benefit attached to them. If the applicant already has a Lifeline discount, the agent must inform the customer that he/she must choose which Lifeline service to receive. If they chose to enroll with us, the enrollment will be reported to the federal government, and they will lose the benefit provided on their previous phone. Note: If a customer has been receiving lifeline benefit for less than 60 days from a previous carrier, we cannot transfer the service to Safelink. Only those customers that have been with other carriers for more than 60 days are allowed to transfer to Safelink. A household is a collection of persons that live together and share income or expenses. Separate households that live at the same residential address may receive separate Lifeline benefits. For example, a two-story house may not have the apartments or floor numbers officially registered on USPS, but more than one family may be living in there. In order to have two supported services at the same residential address customers must complete the USAC Multiple Household Worksheet. Note: DO NOT give the customer the USAC Multiple Household Worksheet if someone in their household already receives Lifeline. Safelink Service Safelink Wireless provides free cell phones for people that qualify for the service at Safelink s cost. Customers cannot choose the model or the brand. The devices have a color screen, contact list, games, and include earphones battery and charger. The shipping and handling of the cell phone and any documentation involved are free. This means that there will be no mailing charges either to send or receive any paperwork or phones. Customers will get a certain amount of free minutes, depending on the plan they choose. If they need more minutes, they have the option to buy Tracfone prepaid cards. Safelink phones only accept TracFone cards.

Fraud and Misconduct SafeLink is a Lifeline supported service. Lifeline is a benefit program administered by the federal government. The federal government considers acts of fraud or misconduct related to Lifeline to be of the utmost seriousness. People illegally defrauding the Lifeline system have been subject to criminal prosecution and imprisonment. TracFone has zero tolerance for any acts of fraud or misconduct. Customer Consent To enroll in Safelink, a customer must certify that they meet the qualification criteria and agree to the terms of Lifeline service. Customers must read, and personally check all of the boxes contained in Section 3 of the application form, including their signature under penalty of perjury. Agents are NOT PERMITTED to fill out this part of the application form. When this part of the application is reached, allow the customer to check the required boxes. DO NOT CHECK THEM YOURSELF. Misrepresentations Concerning Lifeline Any misrepresentations concerning the Lifeline program will be taken with the utmost seriousness. This includes misrepresenting the eligibility criteria (such as suggesting that ineligible programs like Medicare can be used to qualify for Lifeline), or misrepresenting the one-per-household rule. Marketing FCC rules and applicable law impose certain requirements on marketing material for Lifeline. Agents are only permitted to use marketing material provided by SafeLink. DO NOT CREATE ANY MARKETING MATERIAL ON YOUR OWN, including fliers, email solicitations, or other material. You are only authorized to solicit customers as Field Agents at the locations specified by SafeLink. You are NOT PERMITTED to conduct any solicitation of customers by phone, email, or ANY OTHER MEANS. You are NOT PERMITTED to collect information from customers for later submission. You are NOT PERMITTED to use SafeLink in any email address for any purpose.

Promotional Codes You will be issued a unique promotional ( promo ) code to track your enrollments and commissions. Your promo code is authorized for your use only. DO NOT share your promo code, or the tablet with the enrollment software. You will be held responsible for any misuse of your promo code. Don ts Other Don ts - Do not use invalid proofs - Do not use the same benefit card for different applicants - Do not manipulate personal information in order to surpass validation issues while creating a new application. - Do not use a benefit recipient s information to create a second application - Do not submit blurry or unreadable proofs Never sign for customers or on customer s behalf. Never send phones to your personal home address. Never share your log-in information/promotional code with other agents. Never use non approved tablets or equipment to process applications. Customers must always be physically present when applying for service. Never enroll customers over the phone. Always report computer glitches or errors. Never copy customers personal information. Never sign up customers in unauthorized areas. Prior approval is required to approach customers at any location. Never approach customers at government agencies or social service agencies without proper permission.

Whistleblower Policy If you have information concerning a violation of these rules, you must contact TracFone to report it. We will keep your identity confidential from your employer. You may contact us through the following means: By phone Wrongdoing Hotline 800-208-1176. By mail: Wrongdoing, PO Box 160670, Hialeah, FL 33016 By e-mail: Wrongdoing@TracFone.com Your report must include sufficient and specific details regarding source and names of person(s) involved in violation of SafeLink program rules. Provide us with your name and contact information. Report only program rule violations. You must not use this facility to report other types of issues; for example, wage disputes and other issues with your employer. Lifeline is a federally supported service and is regulated by the Federal Communications Commission (FCC). Only qualified customers can participate and any agent, person, entity or group helping or acting in any way to enroll customers who do not qualify will be criminally persecuted to the highest extent of the law.

Certification of SafeLink Compliance Training Field Agent s Certification I certify that I have received and reviewed the SafeLink Compliance Manual setting forth TracFone s Lifeline enrollment procedures that field agents will follow to help ensure TracFone s compliance. I also certify that I have completed the Compliance Training Program regarding these matters. I agree to comply with all of the rules contained herein. Signature Printed Name Date Contact Number Agency/Subcontractor Certification I certify that I have provided a copy of the SafeLink Compliance Manual setting forth TracFone s Lifeline enrollment procedures that field agents will follow to help ensure TracFone s compliance, and reviewed it with him or her to ensure he or she understands it. I also certify that I have provided the required Compliance Training. Signature Printed Name Title Company Date