Home Legal Fraud & Compliance Policy

Fraud & Compliance Policy

This policy exists to protect the partners who do the work properly. Clear rules, visible evidence, and a decision made by a person — not a silent algorithmic ban.

We reward legitimate performance

Consistent, compliant production raises your Trust Score, which unlocks Preferred Partner status: early access to new campaigns, premium payout tiers and higher volume caps. Partners who operate cleanly are the ones this network is built for.

We act decisively on what isn't

Manipulated or fraudulent activity is not a grey area. It gets investigated with evidence, it is not paid, and — where confirmed — it ends the relationship. This is stated plainly here so no partner is surprised later.

Draft for design purposes — not legal advice
The enforcement, withholding and recovery provisions below must be reviewed by counsel and reconciled with the Center Partner Agreement and applicable law before publication.

1. Principles

  • Evidence before accusation. Every action is grounded in specific, reviewable evidence.
  • A person decides. Automated detection raises alerts; it does not issue verdicts.
  • Proportionate response. A first-time quality issue is handled differently from deliberate manipulation.
  • Right of reply. Partners see what was found and can respond before a final determination, except where immediate suspension is necessary to prevent ongoing harm.
  • Consistency. The same standard applies to every partner regardless of volume or tenure.

2. Invalid activity

Activity that is not billable and not payable, whether or not it was intentional:

  • Transfers or leads that do not meet the campaign's published qualification criteria
  • Duplicate submissions of the same consumer within the campaign's defined window
  • Contacts made outside permitted hours, geography or consent scope
  • Records with falsified, incomplete or unverifiable consumer information
  • Calls where required disclosures were not made
  • Transfers where the consumer did not consent to the transfer or did not intend to proceed
  • Activity generated from non-compliant, unverified or prohibited traffic sources

3. Prohibited conduct

The following are treated as serious breaches:

  • Fabricating consumer records or consent
  • Incentivizing, coaching or misleading consumers to meet qualification criteria
  • Manipulating call duration, dispositions, timestamps, routing or tracking
  • Recycling, reselling or re-submitting previously delivered records
  • Using agents or facilities not disclosed during verification, including undisclosed subcontracting
  • Misrepresenting capacity, licensing, infrastructure or ownership during qualification
  • Operating a campaign a center is not certified on
  • Attempting to access another participant's data
  • Circumventing the Platform to transact directly with an introduced counterparty

4. How we detect

Detection is continuous and multi-signal. Monitored indicators include unusual call patterns, duplicate rates, abnormal conversion rates relative to campaign and network benchmarks, sudden volume spikes, tracking anomalies, disposition distributions, consumer complaints, buyer rejection patterns and QA scoring outcomes. Signals are scored by severity and routed to the internal Fraud & Risk queue.

5. Investigation process

Alert raised (automated or reported) Triage & severity assignment Evidence assembled & reviewed by a person Partner notified & given right of reply Determination & action, logged

Where activity presents an ongoing risk to consumers or a campaign owner, access may be suspended immediately while the investigation proceeds. Suspension is a protective step, not a finding.

6. Consequences

Depending on the findings, one or more of the following may apply:

  • Rejection of the affected activity and non-payment for it
  • Withholding of payment on activity under investigation until the review concludes
  • A reduction in Trust Score and a change in partner tier
  • Removal from a specific campaign
  • Immediate suspension of Platform access pending investigation
  • Termination of the partner relationship
  • Recovery of amounts previously paid on activity later determined to be fraudulent or invalid, and recovery of associated losses, in each case to the extent permitted by applicable law and the Center Partner Agreement
  • Referral to the campaign owner, to regulators or to law enforcement where warranted

PLACEHOLDER: counsel to confirm the withholding, clawback and set-off mechanics and their enforceability in the governing jurisdiction.

7. Right of reply & appeal

Partners receive the specific findings, the evidence relied on, and a defined window to respond. A determination may be appealed once to a reviewer who was not involved in the original decision. Rejections of individual leads follow the campaign's dispute window and do not affect Trust Score until that window closes.

8. Compliance obligations

Independently of fraud, every partner is responsible for its own compliance with applicable telemarketing, do-not-call, consent, recording and privacy law. Campaign-level compliance review by the Platform is an internal quality control and does not transfer that responsibility.

PLACEHOLDER: counsel to enumerate the applicable statutory frameworks and any vertical-specific obligations.

9. Reporting a concern

Campaign owners, partners, consumers and members of the public can report a concern. Reports are reviewed by the compliance team and are treated confidentially where possible. PLACEHOLDER: compliance reporting email and phone number. Consumers who believe they received a non-compliant call should use the contact form and select "Compliance or legal".