How we handle complaints.

Action Oriented BPO

Consumer Complaint Review, Investigation and Handling Policy

Policy number	AOB-CMP-001	Version	1.0
Effective date	September 1, 2026	Next review	September 1, 2027
Policy owner	Muneeb Inam, Compliance Officer	Approved by	Founder & CEO
Applies to	All employees, contractors and vendors of Action Oriented BPO ("AOB", "we", "us")

1. Purpose

This policy sets out how Action Oriented BPO receives, records, investigates, resolves and learns from consumer complaints. Its aims are to treat every complainant fairly and promptly, to stop unwanted contact quickly, to identify and correct compliance problems in our advertising and call delivery, and to keep complete records that show how each complaint was handled.

2. Scope

2.1 This policy applies to any complaint made by or on behalf of a consumer about:

• advertising campaigns we build, run or fund, including ad content, targeting and disclosures;
• calls, texts or other contact connected with our campaigns, including requests to stop contact;
• the collection, use, sharing or security of a consumer's personal information;
• the conduct of anyone acting for AOB; and
• the conduct of a partner agency or licensed agent that received a call through one of our campaigns, to the extent described in Section 12.

2.2 Disputes raised by partner agencies about billing or call quality are handled under our partner agreements and are not consumer complaints, unless they include a consumer complaint, in which case that part is handled under this policy.

3. Policy statement

AOB treats every complaint as an opportunity to protect consumers and improve our operations. We will:

• accept complaints through any reasonable channel, in any form, free of charge;
• stop contact with any consumer who asks us to, without requiring a formal complaint;
• acknowledge every complaint within one (1) business day;
• begin an impartial investigation within forty-eight (48) hours of receipt;
• give the complainant a clear written outcome, normally within fifteen (15) business days;
• fix what went wrong, for the complainant and for others affected; and
• never retaliate against anyone for making a complaint.

4. Definitions

Complaint

Any expression of dissatisfaction, oral or written, about the matters listed in Section 2, whether or not the person uses the word "complaint". A request to stop contact is always treated as a complaint for logging and suppression purposes.

Complainant

The consumer making the complaint, or a person authorized to act for them (for example a family member, caregiver, attorney or regulator).

Partner agency

A licensed insurance agency or agent that receives inbound qualified calls from AOB campaigns.

Compliance Officer

The person designated by the Founder & CEO to own this policy. Currently: Muneeb Inam, Compliance Officer.

Complaint Handler

The team member assigned by the Compliance Officer to log, acknowledge and manage a complaint.

Suppression

Removing a consumer's phone number and other identifiers from all AOB ad targeting, retargeting and contact lists so they are not contacted again through our campaigns.

Business day

Monday to Friday, excluding US federal holidays.

5. Roles and responsibilities

• All staff and contractors must recognize a complaint, record the complainant's details and pass it to the Complaint Handler on the same business day. Anyone who receives a stop-contact request must act on it as described in Section 7.
• Complaint Handler logs and acknowledges complaints, applies suppression, gathers records, keeps the complainant informed and drafts the response.
• Compliance Officer owns this policy, assigns investigations, makes or approves findings, decides remedies and corrective actions, handles escalations and regulator contact, and reports on complaint trends.
• Founder & CEO approves this policy, decides escalated complaints, and makes sure the Compliance Officer has the authority and resources to carry it out.

6. How complaints can be made

6.1 Consumers may complain by any of the following:

• Online form: actionorientedbpo.com/complaint-policy.html
• Email: management@actionorientedbpo.com
• Phone: +1 (512) 559 7003
• Mail: Attn: Muneeb Inam, Compliance Officer, Action Oriented BPO, 5900 Balcones Drive, Austin, TX 78731
• Through a partner agency, carrier, ad platform or regulator that forwards the complaint to us.

6.2 We accept complaints made verbally, in writing or through a representative. We do not require a particular form or wording, and we will help a complainant put their complaint into words if needed.

6.3 This policy and the ways to complain are published on our website and linked from our Compliance page.

7. Receipt, logging and acknowledgment

7.1 Stop-contact requests. When a consumer asks not to be contacted, their number and identifiers are suppressed from all AOB targeting, retargeting and contact lists within one (1) business day. Where the consumer's details were shared with a partner agency, we notify that agency of the request within the same period.

7.2 Logging. Every complaint is entered in the Complaint Log within one (1) business day of receipt and given a unique reference number. The log records the information listed in Appendix A.

7.3 Acknowledgment. The complainant is sent an acknowledgment within one (1) business day by their preferred channel. It includes the reference number, a summary of the complaint as we understand it, the name or role of the contact person, and the expected timeline.

7.4 Anonymous complaints are logged and investigated as far as the information allows.

8. Classification and priority

8.1 The Compliance Officer may raise the priority of any complaint. A suspected data security incident is also handled under our incident response procedures, and any legally required breach notifications are made within the time the law requires.

9. Investigation

9.1 Investigations are carried out by a person who was not involved in the matter complained about. The Compliance Officer assigns the investigator.

9.2 The investigation will, as relevant:

• review call records, including call source, timestamp, duration, campaign attribution and any recording;
• review the ad creative, copy, targeting settings and disclosures that were live at the time;
• review the consent and contact history for the complainant's number;
• interview the staff, contractors or partner agency involved; and
• speak with the complainant if more information is needed.

9.3 Relevant records are preserved from the moment a complaint is received and are not deleted while the complaint, or any related dispute or inquiry, is open.

9.4 The investigator records the facts found, the evidence relied on, a finding of substantiated, partially substantiated or not substantiated, and the cause.

10. Resolution and response

10.1 The complainant receives a written response by their preferred channel that explains what we found, what we have done, and what they can do if they are not satisfied (Section 11).

10.2 Remedies may include suppression and confirmation that contact has stopped, deletion of personal information where we are able to and the law allows, correction or removal of an ad, retraining or other action involving staff, action involving a partner agency, and an apology where appropriate.

10.3 If we need more time than the target in Section 8, we tell the complainant before the target date, explain why, and give a new date. Except where a regulator sets a different timeline, every complaint receives a final response within thirty (30) calendar days of receipt.

10.4 A complaint is closed when the response has been sent and all remedies and corrective actions have been completed or scheduled. The Compliance Officer approves the closure of every High priority complaint.

11. Escalation and external options

11.1 A complainant who is not satisfied with our response may ask for a review. The review is carried out by the Compliance Officer, or by the Founder & CEO if the Compliance Officer was involved, and a written decision is sent within ten (10) business days.

11.2 Complainants may contact a regulator at any time; they do not have to use our process first. Depending on the issue, this may include the Federal Communications Commission (unwanted calls and texts), the Federal Trade Commission, their state Attorney General or Department of Insurance, or 1-800-MEDICARE for concerns about Medicare plan marketing. Our response letters include this information.

12. Complaints involving partner agencies

12.1 When a complaint concerns a partner agency or agent who received a call through our campaign, we log it, apply any suppression requested, and forward it to the partner agency within one (1) business day.

12.2 We ask the partner agency to investigate and report back to us in writing, and we track the complaint until we are satisfied it has been addressed. We tell the complainant that the matter has been referred and who is responsible for responding.

12.3 Where a partner agency does not cooperate, or where complaints show a pattern of misconduct, AOB may pause or end campaigns for that partner under the terms of our agreement.

13. Notifications to carriers, partners and regulators

13.1 Where a contract, carrier or plan sponsor requirement, or law requires us to report a complaint, the Compliance Officer makes the report within the required time and records it in the Complaint Log.

13.2 Any inquiry, subpoena or complaint received from a regulator, or any complaint that threatens legal action, is escalated to the Compliance Officer on the same business day, and legal counsel is engaged as needed.

14. Root cause and corrective action

14.1 For every substantiated or partially substantiated complaint, the Compliance Officer identifies the root cause and records a corrective action, an owner and a due date.

14.2 Corrective actions may include changes to ad creative, targeting or disclosures; changes to consent capture or suppression processes; staff retraining; changes to partner agency requirements; and updates to this policy. Completion is verified and recorded.

15. Recordkeeping and retention

15.1 The Complaint Log and all complaint records (correspondence, evidence, findings, responses and corrective actions) are kept for at least six (6) years from the date the complaint is closed, or longer where a law, contract or open matter requires.

15.2 Access to complaint records is limited to staff who need it to handle complaints, compliance, or legal matters.

16. Confidentiality and privacy

Complainants' personal information is used only to investigate, resolve and report on complaints, and to apply suppression. It is shared only with those who need it for those purposes, such as the partner agency involved, a carrier or regulator where required, or our legal advisers. We never sell complaint information.

17. Non-retaliation

No complainant, and no employee or contractor who raises or helps investigate a complaint, will be treated less favorably for doing so. Retaliation is a serious breach of this policy and will lead to disciplinary action.

18. Training

All staff and contractors receive training on this policy when they join and at least once a year. Staff who handle complaints receive additional training on investigation, record keeping, and the laws listed in Section 21.

19. Monitoring and reporting

19.1 The Compliance Officer reviews the Complaint Log at least monthly for open items, missed timelines and recurring issues.

19.2 Each quarter, the Compliance Officer reports to the Founder & CEO on complaint volumes, categories, timeliness, outcomes, root causes and the status of corrective actions.

20. Policy review and exceptions

20.1 This policy is reviewed at least once a year, and sooner if relevant laws, regulations or our services change. Changes are approved by the Founder & CEO and recorded in the revision history.

20.2 Exceptions to this policy must be approved in writing by the Compliance Officer and recorded. No exception may reduce a consumer's legal rights.

21. Related laws, rules and documents

• Telephone Consumer Protection Act, 47 U.S.C. § 227, and FCC rules at 47 C.F.R. § 64.1200
• Telemarketing Sales Rule, 16 C.F.R. Part 310, including National Do Not Call Registry requirements
• CMS Medicare Advantage and Part D communication and marketing requirements, 42 C.F.R. §§ 422.2260–422.2274 and 423.2260–423.2274
• Applicable state telemarketing, insurance marketing and consumer privacy laws
• Meta advertising policies for insurance and financial products
• AOB Compliance page (actionorientedbpo.com/compliance.html) and partner agency agreements

Appendix A: Complaint Log fields

Reference number; date and time received; channel; complainant name and contact details (or "anonymous"); representative, if any; phone number(s) involved; state; category and priority; summary of the complaint; desired outcome; suppression applied (date and by whom); partner agency involved and date referred; acknowledgment date; investigator; evidence reviewed; finding; root cause; remedy; response date; extension notices; escalation and outcome; external reports made; corrective actions with owner and due date; closure date and approver.

Revision history