Enrollment Representative Compliance Manual

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1. INTRODUCTION

TracFone Wireless, Inc. (“TracFone” or “Company”) is committed to achieving and maintaining full compliance with all laws, regulations, and policies governing the conduct of our business. Consistent with that objective, TracFone compiled this Enrollment Representative Compliance Manual (“Compliance Manual”), which provides an overview of the policies and procedures related to the Federal Communication Commission’s Lifeline program. The objective of this compliance framework is to attract and service eligible customers of these programs, while strictly adhering to applicable law.


2. LIFELINE PROGRAM

The Lifeline program is a Federal Communications Commission (“FCC”) program that provides a monthly discount on phone and internet service for qualifying low-income households. Access to affordable voice and internet service is vital to stay connected in today’s world. People need these services to connect with healthcare providers, potential employers, educational programs, and loved ones. Affordable service remains a challenge for many low-income consumers. The federal Lifeline program helps close the gap for these consumers by offering a monthly discount of up to $9.25 (or up to $34.25 for those on Tribal lands) towards a qualified household’s phone or internet service. Under the Lifeline program only one monthly service discount is allowed per household. A household is a group of people who share income and expenses. Consumers who live at the same address as another person already receiving the Lifeline benefit may still be eligible for the discount if they do not share income and expenses with that person. For example, multiple people living at a homeless shelter may qualify for Lifeline.


2.1 Universal Service Administrative Company

The Universal Service Administrative Company (“USAC”) is an independent not-for-profit organization designated by the FCC. USAC administers the Universal Service Fund (“USF”). The USF is almost $10 billion and is available annually thanks to the companies and institutions that make universal service possible. Universal service is money collected from telecommunications companies that is dedicated to fulfilling the goals of universal service programs. Telecommunications companies are required to make universal service contributions under the Telecommunications Act of 1996. USAC administers the collection and disbursement of these contributions. Universal service is based on the principle that all Americans should have access to a baseline level of telecommunications service and further the public interest of keeping all Americans connected. With the guidance of policy created by the FCC, USAC collects and delivers funding through programs focused on places and people where broadband and connectivity needs are not being met.


2.2 National Verifier System

The National Verifier (“NV”) is Lifeline’s centralized application system. It determines whether consumers are eligible for Lifeline. USAC manages the NV and provides customer service to consumers through the Lifeline Support Center. Service providers must use the NV (with the exception of the opt-out states of California, Oregon, and Texas), when helping consumers apply to Lifeline. Consumers may also apply to the Lifeline program on their own through the NV consumer portal, or by mail. The NV has automated database connections to verify consumer eligibility for Lifeline. If a consumer is not found in an automated database, they will need to provide documentation for manual review. California1Oregon, and Texas manage eligibility verification and duplicate checking for the federal Lifeline program in parallel with administering their own state low-income subsidy programs. Additionally, the National Verifier performs reviews of state eligibility information and documentation to ensure that state eligibility determinations are made in accordance with FCC rules.


2.3 Lifeline Program Qualification Criteria

Consumers may qualify for the Lifeline program through their level of income or through participation in a Lifeline-qualifying program.

1 Note there is an exception for standalone broadband subscribers in California, where the state does not verify the eligibility of subscribers. In that instance, the National Verifier verifies consumer eligibility.

2.3.1 Eligibility via Income Level

Note: The Federal Poverty Guidelines are adjusted annually, and the above chart reflects guidelines for 2024.


2.3.2 Examples of Valid Income Eligibility Proofs Only the following will be considered as valid income proofs:

✔ Last 3 months consecutive pay stubs

✔ Last year’s income tax return form

✔ Last year’s W2 form

✔ Letter from the SSA stating the benefits the customer receives per month. Letter cannot be older than 12 months from the current date.

✔ In Florida, customers won’t 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.


Note: Bank statements, checks, and/or currency are not valid income proofs.


2.3.3 Eligibility via Government Assistance Programs

● Supplemental Nutrition Assistance Program (“SNAP”)

    • SNAP programs are administered by the state and may be offered under a variety of different names. See Attachment C for a list of SNAP program names by state.

● Medicaid

    • Medicaid programs are administered by each state and may be offered under a variety of alternative names. See Attachment D for a list of Medicaid program names by state.
    • Note that Medicare is NOT a Lifeline qualifying program. Medicaid provides health insurance to low-income people, whereas Medicare provides health insurance to elderly people without regard to income.

● Supplemental Security Income (“SSI”)

    • Note that SSI is not the same as Social Security. SSI is available only to certain low-income persons, whereas Social Security is not means-tested and not a qualifying Lifeline program

● Federal Public Housing Assistance (“FPHA”)

    • To find contact information for a local Public Housing Agency, visit the U.S. Department of Housing and Urban Development’s state contact and agency listing.

● Veterans and Survivors Pension Benefit

    • Note that the Veteran and Survivors Pension Benefit is a specific government program which provides support to low-income veterans or their surviving spouse or child. It does not confer eligibility on all veterans or beneficiaries of other veterans benefits, such as healthcare through the Veterans Administration.

● In addition to the programs listed above and through the income-qualifying standard, consumers living on Tribal lands may also use the following Tribally-administered programs to qualify for Lifeline.

    • Bureau of Indian Affairs General Assistance
    • Tribally-Administered Temporary Assistance to Needy Families (“TANF”)
    • Tribal Head Start
      • Head Start Program eligibility only refers to those households that have already met the income-qualifying standard. o Food Distribution Program on Indian Reservations (“FDPIR”)
      • Although the FDPIR is a federal program, administered by the Food and Nutrition Service (“FNS”), award letters are generally provided by either an Indian Tribal Organization (“ITO”) or another state agency.
      • Review this map online of state agency contacts for FDPIR to learn more.

2.3.4 Examples of Valid Government Assistance Eligibility 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 FPHA 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 the customer receives or is approved for FPHA.

✔ Note: A card that doesn’t 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).


2.3.5 One Per Household Rule

For the purposes of the Lifeline program, a household is defined as anyone living at the same address who shares income and household expenses. Only one Lifeline benefit is allowed per household.


A Lifeline Household Worksheet (“HWS”) must be completed any time more than one subscriber at a single residential address receives Lifeline-supported service, or when a new consumer applies for service at an address where there is already a subscriber receiving the Lifeline benefit. 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 a second Lifeline benefit. Note that enrolled customers may have other cell phones or landlines, but they must not have any Lifeline benefit attached to them.


Lifeline rules require submission of a residential address with the application. Addresses which are zoned for commercial purposes are eligible, if the customer resides there. This is commonly the case with homeless shelters. Homeless shelters may be considered a valid residential address, if the customer has no other address. Government benefit offices and churches which do not provide overnight accommodations should not be used as residential addresses.


A household is a collection of persons that live together and share income or expenses. It’s possible that separate households living 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 at the address. Note that when an applicant is completing the enrollment process and the HWS is required, the duplicated address error pops-up, and the applicant has to complete the HWS process. The HWS process will ask the customer a series of questions to determine if the customer or someone in their household already receives a Lifeline benefit. DO NOT proactively offer the household worksheet unless the customer informs you that more than one household resides at their address or the initial enrollment attempt generates a response from NLAD indicating someone already receives benefits at that address.


2.3.6 Usage Requirement

Subscribers receiving a free Lifeline-supported service must use their service at least once every 30 days in order to receive their discount. Sending a text message, making an outbound telephone call, answering an incoming call, or using data to go online with your Lifeline device are all considered usage for subscribers receiving free Lifeline supported service. The usage policy only applies to free Lifeline supported service. This usage policy does not apply to customers receiving a Lifeline discount service plan which requires a payment.


2.3.7 Tribal Lands

Customers who reside on Tribal Lands are eligible for an additional $25.00 in monthly Lifeline support. This support extends to all qualified persons living on Tribal Lands, regardless of whether or not they are enrolled members of a Tribe. Only federally-recognized Tribal Lands (including off-reservation areas designated by the FCC) are considered Tribal Lands for the purposes of Lifeline, which excludes certain tribal lands recognized only under state law.


TracFone designated service area in some states excludes Tribal Lands. This means TracFone cannot provide or attempt to enroll customers in basic Lifeline service or Tribal Lifeline on these lands. These states include Colorado, Arizona, New Mexico, New York, Virginia, Connecticut, Massachusetts, Alabama, North Carolina, Tennessee, Delaware, New Hampshire and Pennsylvania. Enrollment Representatives should not conduct Lifeline enrollment activities on Tribal Lands in these states.


2.4 Enrollment Process

The National Lifeline Accountability Database (“NLAD”) allows service providers to enroll eligible consumers in the Lifeline program and manage their Lifeline subscribers. After a consumer qualifies for the Lifeline program through the National Verifier, their service provider must enroll them in the program. In most states (with the exception of California, Oregon, and Texas), service providers use NLAD to enroll their consumers in the Lifeline program.


2.4.1 Role of Enrollment Representatives s in the Enrollment Process

New potential customers may apply for the Lifeline program with qualified, trained Enrollment Representatives. 2 Enrollment Representatives are managed by third party marketing agencies and use approved and provided tablets to assist customers in completing applications and upload necessary proofs for eligibility determinations. A unique promotional (“promo”) code is assigned to each Representative, to track enrollments created. The Lifeline Fraud Loss & Control Team ensures that Enrollment Representatives coming onboard meet the proper criteria and make the final decision of who is provided a promo code to promote the Lifeline program. The Representative will also complete a thorough vetting process, which is covered in a later section of this manual.

2 Enrollment Representatives are not employees of TracFone but rather subcontractors that report directly to their affiliated master agents.

2.4.2 Representative Accountability Database

The Representative Accountability Database (“RAD”) is a registration system that validates the identities of service provider enrollment representatives performing transactions in NLAD and the National Verifier. USAC made registration in RAD mandatory for representatives using NLAD and/or the National Verifier, including to perform eligibility checks, search for a subscriber, enroll, update, transfer, and de-enroll customers. As an Enrollment Representative, you must register in RAD and receive a RAD ID. A RAD ID is a unique number that connects your identity to the transactions you complete in NLAD and the National Verifier. Do not share your RAD ID number with anyone other than your employer and TracFone.


RAD registration is a two-step process:

1) Representatives self-register for a RAD ID, which will be needed to perform transactions in NLAD and the National Verifier.

2) Representatives provide their RAD ID number to the service provider for which they work. Service providers will use the RAD ID to create the representative’s NLAD and/or National Verifier account credentials.


NOTE: TracFone does not permit Enrollment Representatives to represent TracFone and any other Lifeline providers at the same time. Any attempt to work for an additional Lifeline provider while engaged as a TracFone Enrollment Representative will be treated with the utmost seriousness, up to and including removal from the TracFone program as an enrollment representative.


2.4.3 Emerios – Third Party Vendor for TracFone

Emerios is a third-party vendor that handles the enrollment application process on behalf of TracFone. This vendor is in charge of maintaining interfaces to communicate with TracFone systems, NLAD, and National Verifier systems. Emerios is also responsible for conducting TracFone’s Lifeline Compliance Trainings for its Enrollment Representatives as well as internal TracFone employees.


3. Tracfone Lifeline Brands

SafeLink Wireless® is Tracfone’s main brand through which Lifeline discounts are provided. SafeLink Wireless® offers free cell phone service to Lifeline qualified low-income consumers.

Other Brands Offering Discounts include:

    • Simple Mobile
    • Straight Talk
    • Total Wireless
    • WalMart Family Mobile

3.1 Lifeline Services are available in the following states and territories:

Alabama (AL) Arizona (AZ) Arkansas (AR) Connecticut (CT) Colorado (CO) California (CA) D. of Columbia (DC) Delaware (DE) Florida (FL) Georgia (GA) Hawaii (HI) Idaho (ID) 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) North Dakota (ND) Ohio (OH) Oklahoma OK) Pennsylvania (PA) Puerto Rico (PR) Rhode Island (RI) South Carolina (SC) Tennessee (TN) Texas (TX) Utah (UT) Virginia (VA) Vermont (VT) Washington (WA) West Virginia (WV) Wisconsin (WI) Wyoming (WY).


4. MARKETING, ADVERTISING & ENROLLMENT MATERIALS

FCC rules and applicable law impose certain requirements on marketing material for Lifeline. Enrollment Representatives are only permitted to use marketing material provided by TracFone Wireless, Inc. As an Enrollment Representative you’ll be provided with TracFone marketing materials to encourage eligible customers to sign up for Lifeline using a tablet also provided by TracFone specifically for the enrollment process. You will receive comprehensive training enabling you to make a meaningful difference in eligible customers’ lives by helping them to obtain discounts on services allowing them to connect with what matters to them.


DO NOT CREATE ANY MARKETING MATERIAL ON YOUR OWN - including fliers, email solicitations, or other material.


Additionally, you are only authorized to solicit customers in person at the locations specified by TracFone. You are NOT PERMITTED to conduct any solicitation of customers by phone, email, or ANY OTHER MEANS, such as social media.


You are NOT PERMITTED to collect information from customers for later submission. You are NOT PERMITTED to use TracFone Brands in any email address (i.e. SafelinkWireless@) for any purpose.


Enrollment Representative Compliance Manual Lifeline Some areas may require a business permit or license to market products in public places. It is your responsibility (along with your agency) to comply with these local laws. Failure to do so may result in fines or other penalties.


5. ENROLLMENT REPRESENTATIVE ONBOARDING AND TRAINING


5.1 Vetting Process and Background Checks

All Enrollment Representatives will go through a vetting process consisting of the following prior to being admitted for onboarding and training:

1. Prospective Candidates Information – Lifeline Fraud Loss & Control Team receives a packet via email at agentcertificates@tracfone.com with required documentation from your agency containing the following documents:

✔ Authorization Form

✔ Full name, current address, time at current address, two other former addresses,

email address, phone number, signature and date.

✔ Disclosure Form

✔ Compliance Training Certificate

✔ Driver’s License or State ID

✔ Background Checks Certificate

✔ There is a turnaround time of 24 hours for BA&FM to make a final decision or request

additional documentation or correction to the documents submitted.


2. Final Decision – If the request is approved, an email will be sent to your agency advising that the request has been approved and the enrollment representatives are to call TracFone’s vetting department to authenticate their identity.

✔ If the vetting request is “returned,” you’ll need to provide required/missing documents and resubmit the request through your agency.

✔ If the request is denied, an email will be sent to your agency communicating the final decision.


5.2 Mandatory Enrollment Representative Registration

As discussed above in Part 2.4.2 of this Manual, Enrollment Representatives must register in RAD before they can interact with customers and submit information to the National Lifeline Accountability Database or the National Verifier. As part of the registration process, Enrollment Representatives will be required to provide USAC with identifying information, which may include first and last name, date of birth, the last four digits of his or her social security number, email address, and residential address. Enrollment Representatives will be assigned a unique RAD ID, which must be used for:

(A) Accessing the National Lifeline Accountability Database;

(B) Accessing the National Verifier;

(C) Accessing any eligibility database; and

(D) Completing any Lifeline enrollment or verification forms.


Enrollment Representatives are required to recertify their status annually with USAC to maintain their RAD ID and maintain access to the systems that rely on a RAD ID. Enrollment Representatives must update their registration information with USAC within 30 days of any change in such information.


5.3 Mandatory Annual Training

All Enrollment Representatives must complete a mandatory training module and pass the accompanying knowledge test prior to engaging in any field work. Additionally, this training must be retaken on an annual basis.

Enrollment Representatives will be provided with comprehensive training to utilize the Quest Application, which streamlines the customer enrollment process.


5.4 Promotional Codes

As an Enrollment Representative you will be issued a unique promotional (“promo”) code to track your enrollments. 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.


5.5 Badges

Once you have successfully passed the background and criminal history checks, completed registration and training, you will be provided with an identification badge. You will be issued an identification badge containing your name and photo, which you must wear at all times when representing TracFone for the purposes of soliciting customers to enroll in Lifeline.


All enrollment representatives, after logging in, will be required to take a picture of themselves holding their badge. This will be required only once a day after login. In addition, enrollment representatives will be able to print their badge directly from the enrollment application.


5.6 Enrollment Representatives Expectations and Discipline for Misconduct

TracFone has a zero-tolerance misconduct approach and any misrepresentations concerning the Lifeline program will be taken with the utmost seriousness, up to and including termination of your promo codes and reassignment by your associated master agent. This includes, but is not limited to, misrepresenting the eligibility criteria (such as suggesting that ineligible programs like Medicare can be used to qualify for Lifeline), misrepresenting the one-per-household rule, or working for TracFone and another Lifeline provider at the same time.

The following examples demonstrate scenarios of misconduct that will not be tolerated.

❖ Example 1: Improper usage of assigned unique promo codes, such as sharing with other Enrollment Representatives.

❖ Example 2: Inappropriate use of TracFone branded marketing materials and prohibition of any personal marketing materials.

❖ Example 3: Solicitation of customers outside of locations specified by TracFone – Enrollment Representatives are only authorized to solicit customers at the geographic locations specified by TracFone.

❖ When working as an Enrollment Representative:

- Do not use invalid eligibility proofs.

- Do not use the same benefit card for different applicants.

- Do not manipulate personal information in order to bypass 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.

- Do not process enrollments using a non-residential address. A government benefits

office cannot be used as a customer’s residential address.

- Never share your log-in information/promo code with other representatives.

- Never use non approved tablets or equipment to process applications.

- Customers must always be physically present when applying for service.

- Never copy or otherwise retain a customer’s personal information.


5.7 Enrollment Representative Audit Tool

When enrolling a customer in Lifeline, a photo is taken of the applicant during the e-signature section before submitting the application to the National Verifier as an additional internal control. A photo of the enrollment representative is also taken at the beginning of enrollment flow. Once the enrollment process is completed and e-signed by the applicant, the photographs shall be sent to TracFone for review.

1. If the enrollment representative’s picture is different than the picture in the enrollment representative’s profile, the enrollment will be rejected.

2. If the customer’s picture is the same as the enrollment representative’s picture, the enrollment will be rejected.


6. WHISTLEBLOWER POLICY AND DUTY TO REPORT VIA COMPLIANCE HOTLINE


6.1 How to Report Violations

If you have information concerning a violation of these rules, you must contact us to report it. We will keep your identity confidential from your employer. You may contact us through the following means:

Anonymous Compliance Hotline: 1-844-894-8433

Email: ethics@verizon.com

Online Reporting Portal: https://verizon.speakfullynow.com


6.2 Information Report Should Include

Your rule violation report should include sufficient and specific details regarding source and names of person(s) involved in violation of program rules.

✔ You have the right to remain anonymous or provide your name and contact information.

✔ Report program rule violations in as much detail as possible.

✔ You should not use this channel to report other types of issues such as wage disputes and other issues with your employer.


6.3 USAC Whistleblower Contact Information

If you are aware of any program violations involving Lifeline, USAC encourages reporting such violations via the below hotline or email contact information. You may choose to remain anonymous when reporting potential rule violations to USAC.

Whistleblower Hotline: 1-888-641-8722

Email: potentialviolation@usac.org



7. CONFIDENTIALITY

As an Enrollment Representative you will perform services for the Company that may require TracFone to disclose confidential and proprietary information to you. Confidential Information is information and data of any kind concerning any matters affecting or relating to TracFone, the business or operations of TracFone, and/or the products, drawings, plans, processes, or other data of TracFone, not generally known or available outside of the Company. Accordingly, to protect the Confidential Information that may be disclosed to you as an Enrollment Representative, you should be aware of the following policies to which all Enrollment Representatives must agree to comply with in a Confidentiality Agreement, which appears at the end of this Compliance Manual.


A. Enrollment Representatives will hold the Confidential Information received from TracFone in strict confidence and will exercise a reasonable degree of care to prevent disclosure to others.

B. Enrollment Representatives will not disclose or divulge either directly or indirectly the Confidential Information to others unless first authorized to do so in writing by TracFone management.

C. Enrollment Representatives will not reproduce the Confidential Information nor use this information commercially or for any purpose other than the performance of their duties for TracFone

D. Enrollment Representatives will, upon request or upon termination from TracFone’s Lifeline program, deliver to TracFone any drawings, notes, documents, equipment, and materials received from TracFone or originating from acting as a Enrollment Representative for TracFone.

E. Enrollment Representatives recognize the highly confidential nature of customer information collected during the enrollment process for Lifeline (such as names; addresses; last 4 of Social Security Numbers; verification documents - including proof of government program participation or income; and any other information that can be reasonably described as Personally Identifiable Information) and agree not to disclose this information to any other person or entity, nor retain any originals or copies of the customer’s proof of eligibility documentation or application.


8. PROHIBITION ON COMMISSIONS FOR ENROLLMENT REPRESENTATIVES AND SUBCONTRACTORS

Federal Regulations mandate that participating service providers shall not offer or provide to enrollment representatives (aka Enrollment Representatives ), their direct supervisors, or entities that operate on behalf of the participating provider, any form of compensation that is:


  • based on the number of consumers or households that apply for or are enrolled in the Lifeline with the participating provider;
  • based on revenues that the participating provider has received or expects to receive in connection with the Lifeline, including payments for connected devices.

ENROLLMENT REPRESENTATIVES CANNOT BE PAID ON A PER-ENROLLMENT BASIS. IF YOUR AGENCY PROMISES TO PAY YOU A COMMISSION FOR EVERY LIFELINE ENROLLMENT YOU COMPLETE, CONTACT US VIA THE WHISTLEBLOWER HOTLINE.


9. GLOSSARY AND COMMONLY USED ACRONYMS


Attachment “A”

Compliance Manual Certification

Enrollment Representative’s Certification


I certify that I have received and reviewed the Enrollment Representative Compliance Manual setting forth TracFone’s Lifeline enrollment procedures that Enrollment Representatives must follow to help ensure TracFone’s compliance with applicable federal and state regulations.


I agree to comply with all of the rules contained within TracFone’s Enrollment Representative Compliance Manual.


____________________

Signature


____________________

Printed Name


____________________

Date


____________________

Contact Number



Attachment “B”

Enrollment Representative Confidentiality Agreement


This agreement is made between _____________________ ("Subcontractor") and TracFone Wireless, Inc. on __________________20___.


Subcontractor will perform services for TracFone Wireless, Inc. (“TracFone”) that may require disclosure of confidential and proprietary information, as well as customer Personal Identifiable Information (collectively "Confidential Information") to Subcontractor. Personal Identifiable Information (PII) consists of unique personal identification numbers or data, including Social Security Numbers; Taxpayer Identification Numbers; Employer Identification Numbers; State or foreign driver's license numbers; and Date of birth.


Accordingly, to protect the Confidential Information that will be disclosed during employment, the Subcontractor agrees as follows:


A. Subcontractor will hold the Confidential Information received from TracFone and from customers during the enrollment process in strict confidence and will exercise a reasonable degree of care to prevent disclosure to others.


B. Subcontractor will not disclose or divulge either directly or indirectly the Confidential Information to others unless first authorized to do so in writing by TracFone management.


C. Subcontractor will not reproduce the Confidential Information nor use this information commercially or for any purpose other than the performance of their duties for TracFone.


D. Subcontractor will, upon request or upon termination of their relationship with TracFone, deliver to TracFone any drawings, notes, documents, equipment, and materials received from TracFone or originating from employment with TracFone.


E. TracFone will have the sole right to determine the treatment of all inventions, writings, ideas and discoveries received from Subcontractor during the period of employment with TracFone, including the right to keep the same as a trade secret, to use and disclose the same without prior patent applications, to file copyright registrations in its own name, or to follow any other procedure as TracFone may deem appropriate.


F. TracFone reserves the right to take disciplinary action, up to and including termination, for violations of this agreement in addition to pursuing civil or criminal penalties.


G. This agreement will be interpreted under and governed by the laws of the state of Florida.


H. All provisions of this agreement will be applicable only to the extent that they do not violate any applicable law and are intended to be limited to the extent necessary so that they will not render this agreement invalid, illegal or unenforceable. If any provision of this agreement or any application thereof


I. will be held to be invalid, illegal or unenforceable, the validity, legality and enforceability of other provisions of this agreement or of any other application of such provision will in no way be affected thereby. Subcontractor represents and warrants that they are not under any pre-existing obligations inconsistent with the provisions of this agreement. Signing below signifies that the Subcontractor agrees to the terms and conditions of the agreement stated above.


__________________________________ ____________________________________ Subcontractor/Subcontractor TracFone Representative Name/Title



__________________________________ ____________________________________ Subcontractor/Subcontractor Signature TracFone Representative Signature



___________________________________ _________________________________

Date Date



Attachment "C" Supplemental Nutrition Assistance Programs (SNAP) by State


Attachment “D” Alternative Names for Medicaid by State

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