Do Not Call (DNC) Policy

Pathway Financial, LLC respects consumer privacy and complies with all applicable federal and state telemarketing regulations, including the Telephone Consumer Protection Act (TCPA) and the FTC Telemarketing Sales Rule (TSR).

This Do Not Call (DNC) Policy explains how Pathway Financial manages marketing calls, honors consumer requests to stop receiving calls, and ensures compliance with applicable regulations.

National Do Not Call Registry

Sales representatives of Pathway Financial must not call any phone number listed on the U.S. National Do Not Call Registry unless one of the following applies:

• The consumer has provided prior written consent to be contacted
• There is an existing business relationship with the consumer within the previous 18 months

Consumers may register their phone numbers with the National Do Not Call Registry at: https://www.donotcall.gov

Internal Do Not Call List

Pathway Financial maintains its own Internal Do Not Call (DNC) List.

This list includes individuals who:

• Have requested not to receive future calls from Pathway Financial
• Have filed complaints regarding calls or communications

All team members involved in outbound calling must review the internal DNC list before initiating any call.

Any request from a consumer to be added to the Internal Do Not Call List must be honored immediately and documented in the company’s CRM system.

Telephone numbers added to the Internal Do Not Call List will remain on the list for at least five (5) years unless the consumer requests removal.

Call Time Restrictions

Outbound sales or marketing calls may only be placed between:

• 8:00 AM and 9:00 PM local time of the person being contacted

Pathway Financial team members must respect these time restrictions and ensure that calls are placed only within the permitted time window.

Caller Identification Requirements

During every outbound call, Pathway Financial representatives must:

• Clearly state their full name
• Identify that they are calling on behalf of Pathway Financial, LLC
• Provide a valid phone number or email address the consumer can use to contact the company

Representatives must communicate in a clear and truthful manner and must not misrepresent the purpose of the call.

Consumer Requests to Stop Calls

If a consumer asks not to receive future calls from Pathway Financial, the request must be:

• Honored immediately
• Recorded in the company CRM system
• Added to the Internal Do Not Call List

Once added to the Internal Do Not Call List, Pathway Financial will take reasonable steps to ensure that marketing calls are no longer made to that number.

SMS Communications

If a consumer has provided consent to receive text messages from Pathway Financial, they may opt out at any time.

To stop receiving text messages, reply STOP to any message.

For assistance, reply HELP.

Message and data rates may apply. Message frequency may vary.

Prohibited Practices

The following practices are strictly prohibited:

• Calling any phone number listed on the National Do Not Call Registry without a qualifying exception
• Calling any number listed on the Internal Do Not Call List
• Ignoring or failing to process consumer Do Not Call requests
• Failing to properly document a Do Not Call request in the CRM system
• Sharing, selling, or distributing Do Not Call information

Team Responsibilities

Pathway Financial requires all employees and representatives involved in telephone communications to comply with this policy.

Sales Representatives

• Must review DNC lists before initiating calls
• Must document all Do Not Call requests immediately

Supervisors and Managers

• Must monitor and audit calls for compliance
• Must verify that DNC procedures are being followed

All personnel involved in telemarketing activities receive DNC compliance training upon hiring and periodic refresher training thereafter.

Violations and Penalties

Failure to comply with this policy may result in disciplinary action, including termination of employment.

Violations may also expose the company and the individual involved in legal liability under applicable telemarketing laws.

Questions or Reporting Concerns

For questions about this Do Not Call Policy or to report a potential violation, please contact:

Compliance Department

Email:support@pathwayfinancial.com

Phone:+1 (888) 844-3508