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DIRECTV DS
Red Alert
Policy
Fraud Management Process
Effective June 2010




                                DIRECTV Direct Sales
                                The information covered in this policy includes, but not
                                limited to, creating fraudulent transactions and activities,
                                misleading customers, creating fraudulent sales, call
                                avoidance, slamming, cramming, keeping/storing of
     VXI Global- QA Dept.
                                customer’s confidential information and any acts of
 SM Cyber2 Jupiter and          discourtesy. This policy covers all employees assigned to
     Zodiac Sts. Corner         DIRECTV, regardless of position, directly or indirectly
  Buendia Ave., Makati          involved in the transactions and activities.
  City Philippines 1226

              + (632)899.2200

        Fraud Management
                  Process
VXI Global – DIRECTV Red Alert Policy


           Policy Statement


This policy shows the rules and guidelines formulated or adopted by DIRECTV as VXI Global account to
reach its long-term goals. These principles are designed to influence and determine all major decisions
and actions, and all activities take place within the boundaries set by them. The procedures provided are
the specific methods employed to express policies in action in day-to-day operations of the organization.
Together, policies and procedures ensure that a point of view held by the governing body of an
organization is translated into steps that result in an outcome compatible with the view.

           Objectives


       To inform DIRECTV – assigned employees
        of the QA Red Alert Policy.                     Red Alert Policies are at par with the VXI- Global Fraud
                                                        Management Process and with the most updated DIRECTV Direct
       To apprise DIRECTV – assigned employees         Sales Quality Line Item Definitions – [Section 3.0 Standards |
        of the corresponding penalties for              Legal Compliance]
        infractions of the QA Red Alert Policy.
                                                        Sanctions are at par with client [DIRECTV] guidelines and
       To prevent and manage integrity-related         company COCD | CCC.
        incidents and fraudulent transactions.

           Implementing Guidelines


1. All DIRECTV – assigned employees will be made aware of the different issues that will fall under the
Red Alert Policy during the Training period (for New Hires) and day/s before implementation for existing
DIRECTV – assigned employees.

2. Any violation of the specified policies shall be subjected to sanction as defined.

3. Management reserves the right to place any employee who violates or is suspected to have
committed any of the specified policies on OTP (Off-the-Phone). Concerned employee shall remain on



                                                                                                                    Fraud Management Process
standby while awaiting recommendation from concerned departments.

           Procedure


1. QA will track the sending of these email Alerts then follow up on them to ensure proper disciplines
are adhered to and in line with the disciplinary structure stated.

2. The specified policies have been determined by DIRECTV and VXI Global to be Red Alert Auto Fails and
the following disciplinary actions are to be followed in the steps laid out.

         2.1. The QA Analyst | Verifier will identify a potentially fraudulent transaction or an integrity
related issue.



2|Page
VXI Global – DIRECTV Red Alert Policy

        2.2. The QA2 Analyst will listen to the call for validation.

        2.3. A 2nd QA2 Analyst may have to do a re-validation of the call.

       2.4. The QA Manager validates the incident and categorizes the case into any of the 8 fraud
buckets.

        2.5. The QA Manager enters the incident into the VXI Global Fraud Tracker.

         2.6. The QA Manager informs the Team Lead of the concerned Sales Consultant, including the
Group Manager|Shift Manager, HR|LR and Business Leader about the incident. At the same time, the
sales consultant will be advised by either the Team Lead or Workforce to be off the phones while the
case is under investigation.

          2.7. The case will be discussed within 24 hours and determines validity with Operations through
a Call Listening session.

        2.8. Once validated by both department (Quality Assurance and Operations), a mutual decision
from department managers will be reached regarding the case and it’s sanction. An IR will be issued and
the case will be forwarded to HR|LR for review and processing of necessary documents.



IF   BOTH DEPARTMENT MANAGERS DON ’ T AGREE WITH THE CASE AND SANCTIONS , THE CASE WILL BE

ESCALATED TO    LEVEL 2 FRAUD COMMITTEE (DIRECTOR LEVEL)                     AND CASE SHOULD BE AGREED

UPON AND CLOSED OUT .      FINAL   DECISION AND SUPPORTING DOCUMENTATIONS SHOULD BE FORWARDED

                      TO   HR|LR    WITHIN   24   HOURS FROM TIME OF ESCALATION .




3. Quality Assurance, Workforce Management, Operations and Human Resources Department shall
ensure that necessary and pertinent documentation|reports|recordings|et.al. are completed and made



                                                                                                            Fraud Management Process
available upon endorsement of the case. In cases of dismissal, HR established guidelines and processes
should be followed.

          Administration


Violation of this policy shall merit corresponding disciplinary action as defined under the COCD|CCC
guidelines. The degree of sanction is dependent upon the offense’s classification.

          Details of the DIRECTV Red Alert Policy


The Red Alert issue is categorized into any of the 8 fraud buckets set by VXI Global‘s Fraud Management
Process and will be aligned if not mirrored from the DIRECTV Line Item Definition.



3|Page
Fraud Category 1 – No Proof of Sale
Sanction: Termination of Employment
                               VXI Global – DIRECTV Red Alert Policy




                         EXAMPLES ARE BUT NOT LIMITED TO:


                           Creating fraudulent sales or found to be of no call/s based on CDR.

                           No matching orders found in OOM | OMS, RIO and other DIRECTV – VXI systems.

                           Absence of call recording in DRS and no CDR log entry.

   violated.
   when
   sanction
   and
   details
   scope,
   page, its
   this
   stated on
   category
   the fraud
   policy for
   od the
   understo
   clearly
   dge that I
   acknowle
   page, I
   on this
   my initials
   signing




                                                                                                          Fraud Management Process
   By
   e Initial] -
   [Employe
   _________
   ___________




              4|Page
Fraud Category 2 – Misleading the Customer Where the Information was Critical in Closing the Sale.
Sanction: Termination of Employment
                                 VXI Global – DIRECTV Red Alert Policy

                           EXAMPLES ARE BUT NOT LIMITED TO:


                      Not disclosing the full amount to be charged to the customer’s card. Amount should be clearly
                               explained and broken down [from equipment fees, customer fee based on credit check,
                           taxes, etc.] to the customer.

                           Slurring. – The amount, legal disclosures [RCCs], pertinent information about the package
                                                                     the customer is getting should be clearly disclosed|
                                                                     discussed to the customer. Slurring means:
                       install dates should
                        details or delivery|
                        be disclosed to the




                        information which
                        pertains to pricing

                                                                         o   Not to enunciate words normally or clearly.
                           and promotions




                                                                         o   To pass over lightly or carelessly; treat
                                 customer.




                                  All critical


  violated.
      violated.                                                              without due consideration.
  when
                                                                   If the customer agrees at the time of sales call but
      when
  sanction
                                                                   upon investigation, customer ended up in
      sanction
  and
                                                                   cancelation of the service and complaint because
      and

                       of the misunderstanding of the said disclosures [and matches the part of the call where the SC
  details
      details

                       was observed to be slurring] – then the fraud case will be automatically valid. If there are no
  scope,
      scope,

                       complaints logged in RIO or other DIRECTV-VXI tool at the time of investigation, then further
  page, its its
      page,
                       investigations will be done.
  thisthis
  stated on on
      stated
  category
      category             Providing the customer with promotions | credits that are not supposed to be given or
  thethe fraud
        fraud               combined. Examples are but not limited to:
  policy for for
      policy
  od od the
      the                   o    Combining Referral credits with the Ambassador DNIS
  understo
                                 Taking email address of non-customer just to provide the extra $5 national offer rebate
      understo
                            o
  clearly
                                 and/or not verifying full access to the email account.
      clearly
  dge that I I
      dge that
  acknowle
      acknowle              o    Soliciting ANY email addresses from the customer just to provide the extra $5 national
  page, I I
      page,                      offer rebate.
  on this
      on this
  my my initials
       initials            Guaranteeing the customer with the type and/or number of receivers, packages,
                            promotions that are not matching with the order and policies.



                                                                                                                            Fraud Management Process
  signing
      signing
  By By
  e Initial] - -           Informing the customer that they can call Customer Installation Support for sooner install
                            dates or guaranteeing an installation date.
      e Initial]
  [Employe
      [Employe
  _________
      _________            Telling the customer that they may or will get other promotional discounts after the 12
  ___________
      ___________           month promotional period [24 months for Enhanced markets] or advising the customer to
                            call Customer care for existing offers after the 12/24 month period.

                           Signing the customer up to Preferred Choice and other small international package as an
                            offer to a price point not to fit an international viewing need.

                           Placing the order through Western Union and leading the customer to believe that they
                            have not placed an order.




              5|Page
Fraud Category 3 – No Agreement to Sale. Customer Didn’t Agree to Sale.
Sanction: Termination of Employment
                               VXI Global – DIRECTV Red Alert Policy

                      Informing a customer that they should go to a retailer and purchase a prepaid card to secure
                       their DIRECTV order. The only exception to this policy is if the customer has been educated on
                       the Purchase Option as a prepaid card is a valid form of payment for the Purchase Option.

                      Selling to customers that are ineligible to new offers and/or to customers wherein call should
                       have been transferred to another department. Examples [but not limited to] – Second account
                                      under the same account information, seasonal homes, etc.




violated.
sanction when
details and
page, its scope,
stated on this
fraud category
the policy for the
I clearly understood
I acknowledge that
initials on this page,
By signing my
[Employee Initial] -




                                                                                                                           Fraud Management Process
____________________




                                        EXAMPLES ARE BUT NOT LIMITED TO:


                                     SC charging the customer’s credit |debit card without authorization. This includes
                                      charging the customer’s card after stating that there are no funds or enough
                                      funds to cover the amount disclosed. The only exception is if the customer
                                      proactively told the SC to try and charge the card despite the lack of funds.

                                     Double | Multiple tagging of Sales in CRM |OOM.




              6|Page
Fraud Category 4 – Out of Process [Internal]
Sanction: Termination of Employment
                               VXI Global – DIRECTV Red Alert Policy

                      Customer stated to cancel the order and the SC failed to cancel the order– whether the call got
                       disconnected or not.

                      Customer stated to cancel the order and the SC canceled the order in OOM but still tagged the
                       order as a sale in CRM.

                      For MA|PA orders, the call should be done up to the giving of the account number and Western
                       Union details with instructions to the customer for it to be considered as a sale. If the call gets
                       disconnected prior to this, the SC is expected to cancel the order in OOM and tag it as a non-sale
                       in CRM.




                                                                                  This covers VXI Global’s Internal Procedures
                                                                                  that are directly impacting customer’s
                                                                                  information security, violation of company
                                                                                  policies that are affecting the set SLA’s and
                                                                                  some other processes that were mandated by
                                                                                  DIRECTV.




                         EXAMPLES ARE BUT NOT LIMITED TO:




                                                                                                                                  Fraud Management Process
                      Storing or saving of customer information [i.e. credit | debit card number, SSN etc. al.] on paper
                       or any tools other than those stipulated by management. Said information MUST BE DELETED
                       after every call is made.

                           o   This includes usage of other computer notepads other than what was authorized and
                               approved by VXI Global. [Notepad from DTV Links – 100 character limit]

                      Call Avoidance – is any action where any employee takes action to avoid taking calls. Examples
                       are but not limited to:

                           o   Placing customer on long hold | mute for no valid reason just to elongate the call.

                           o   Placing customer on long hold | mute until the customer hang –up.

                           o   Hanging up on calls while engaged with a customer.



              7|Page
Fraud Category 5 – Unauthorized Use of Customer Credit Card, SSN and other Personal Information
Sanction: Termination of Employment
                               VXI Global – DIRECTV Red Alert Policy

                           o   Telling the customer that he|she is still waiting for the system to upload before she|he
                               can set up the install date or provide the account number when on the DRS screen, it’s
                               already showing the said information.

                      Call back Policy - Once the SC have read the RCCs and processed the credit card (with customer
                                permission), it is considered a SALE.

                           o   If the call drops after this point, agents should flag their Team Manager immediately.

                           o   Team Manager will have the authority to call the customer back to complete the
                               installation portion of order.

                           o   If the call gets disconnected and the SC has not read the RCCs and processed the credit
                               card yet then this is not a sale and NO callback should be made.
      violated.
      when
      sanction
      and
      details
      scope,
      page, its

                         EXAMPLES ARE BUT NOT LIMITED TO:
      this
      stated on
      category
      the fraud               Using other CC or SSN not given by the customer just to process a sale.
      policy for
      od the
                              Alteration of customer’s personal information.
      understo                Illegal use of customer’s credit card.
      clearly
      dge that I              Knowingly setting up service in the name of someone other than the person being
      acknowle                 spoken to.
      page, I
      on this                 The SC must request and receive verbal authorization to do a credit check before the
      my initials              credit check is performed.




                                                                                                                          Fraud Management Process
      signing
                              The SC must get verbal authorization from the CC holder other than the person being
      By                       spoken to. Note: Only if using the SPOUSE’S Card. Even if the card is from a joint
      e Initial] -             account, the name of the customer the SC is speaking to should be the name that
      [Employe                 appears on the card.
      _________
      ___________             Credit being ran by sales consultant on address without the knowledge of the customer
                               or without requesting for SSN. Customer must be aware of how the credit check is being
                               run. i.e. SSN, ITIN or address.

                              SSN and Payment authorization override.




              8|Page
Fraud Category 6 – Misrepresenting Sales Consultant’s Identity and Company’s Credibility
Sanction: Termination of Employment
                               VXI Global – DIRECTV Red Alert Policy




  violated.
violated.
  when
when
  sanction
sanction
  and
and
  details
details
  scope,                 EXAMPLES ARE BUT NOT LIMITED TO:
scope, its
  page,
page, its
                      SC changing his|her job title over the phone to gain authority or for whatever the purpose may
  this
this
                       be.
  stated on
stated on
  category
category
  the fraud           Co-Sales Consultant taking over another SC’s call without authorization from the Team Lead,
the fraud
  policy for           GM, OM or BL [Management].
policy for
  od the
od the
  understo                 o   POC for the day is not considered part of management which means a POC cannot
understo
  clearly                      delegate nor ask another SC to take over someone’s call.
clearly
                      SC was found to have done any act/s of discourtesy. Examples are but not limited to:
  dge that I
dge that I
  acknowle
acknowle
  page, I                  o   Usage of profanity [whether in English or any other language] and argumentative tone.
page, I
  on this
on this
  my initials              o   Sarcastic and sexual remarks | comments while engaged or on-hold with the customer.
my initials
  signing
signing
  By




                                                                                                                        Fraud Management Process
By Initial] -
  e
e [Employe
   Initial] -
[Employe
  _________
_________
  ___________
___________




                9|Page
Fraud Category 7 – Unauthorized Data Entry | Modifications [System Manipulation]
Sanction: Termination of Employment
                                  VXI Global – DIRECTV Red Alert Policy




                         EXAMPLES ARE BUT NOT LIMITED TO:


                      Attempting to cancel existing order|account.
violated.
when
sanction              Changing DNIS call source.
and
details               MA|PA – Western Union Manipulation. Examples are but not limited to:
scope,
page, its                     o   Changing a zip code to a Massachusetts or Pennsylvania zip code to pop the Western
this                              Union option whether the customer has a credit card or not.
stated on                     o   Changing the address of the customer to a MA|PA address not provided by the
category                          customer.
the fraud
policy for            Information entered in OOM | CRM weren’t given by the customer. This includes interchanging
od the                                                 of customer details. Example: Phone number provided by the
understo       System Manipulation which               customer and was heard on the call: (123) 456.7890 and the
clearly        leads to Sales Consultant’s             SC typed (132) 456.7890
dge that I     Financial Benefit [SPIFFs,
                                                           Any manipulation of OOM or CRM in order to achieve a sale.
acknowle
               Bonuses, Commissions and
page, I
               other incentives – whether               Proactively processing a referral credit from an existing
                                                        
on this                                                 customer calling on behalf of a new customer on a non-
               DIRECTV or VXI Global
my initials                                             referral DNIS and the existing customer not specifying that
signing        initiated]                               he|she has been referred. [The word “REFERRED” should be
By                     said or mentioned by the customer].




                                                                                                                          Fraud Management Process
e Initial] -
[Employe              Bypassing any system blocks or pop ups to try and process a sale. Examples are but not limited
_________              to:
___________
                              o    Proactively asking for an alternate phone number from a customer to bypass the
                                  system block.

                              o   Proactively requesting another person’s credit card or SSN to set up an account other
                                  than who is on the phone [not unless customer initiated] and making use of Canadian
                                  SSN to run a credit check

                      Accessing another website which can provide other customer information matching some of
                       those that were provided by the customer on the phone. Example is but not limited to:
                       Accessing www.whitepages.com and typing customer’s name [John Doe] and trying different
                       addresses from the results of the search.



               10 | P a g e
VXI Global – DIRECTV Red Alert Policy

                              o   Only exception is www.USPS.com when the customer is claiming they don’t know the
                                  ZIP CODE to the service address.

                      Making changes on the customer information. [CRM vs. OOM and other systems] Examples are
                       but not limited to:

                              o   Changing the information on CRM after OOM was released. The information in CRM
                                  should ALWAYS match the information in OOM or vice versa.

                              o   Changing the customer information after running the credit check.
violated.
when
sanction
and
details
scope,
page, its
this
stated on
category
the fraud
policy for
od the
understo
clearly
dge that I
acknowle
page, I
on this
my initials
signing
By
e Initial] -
[Employe
_________




                                                                                                                     Fraud Management Process
___________




               11 | P a g e
Fraud Category 8 – Client Escalations
Sanction: Termination of Employment
                                  VXI Global – DIRECTV Red Alert Policy



                         EXAMPLES ARE BUT NOT LIMITED TO:


                      Valid Customer | client complaint. [Complaints already violated by both QA and client].

                                  This includes client – initiated removal.




    violated.
    when
    sanction
    details and
    scope,
    page, its
    stated on this
    category
    the fraud
    the policy for
    understood
    that I clearly
    acknowledge
    page, I
    initials on this
    signing my




                                                                                                                 Fraud Management Process
    Initial] - By
    [Employee
    _____
    _______________




                                      EXAMPLES ARE BUT NOT LIMITED TO:


                                  Required Call Components | Inaccurate Information:


               12 | P a g e
Any Other Auto-Fails Not Classified as Fraud
Sanction: Progressive
                                       VXI Global – DIRECTV Red Alert Policy

                               o       Local channels must be addressed at the beginning or during RCC. Should not read all
                                       channels available. Should cover what is not available specifically. Mention HD if
                                       applicable.

                               o       All other Line Item Definition specified under RCCs and Accurate Information that are




                                                                [OR as stated in the COCD/CCC]




                                                                                                                                                                                                     1st in 90 days – Verbal Warning
                                                                                                                                                                   occurrence –Written Warning
                                                                                                  occurrence – Termination of




                                                                                                                                                                     2nd in 90 days from the first
                                                                                                                                   3rd in 90 days from the first
                                                                                                   4th in 90 days from the first


                                                                                                                                   occurrence – Final Written
                                                                                                                  Employment




                                                                                                                                                                                                                                       Sanctions:
          violated.




                                                                                                                                                      Warning
          when
          sanction
          and
                                       non-fraudulent.
          details
          scope,
          page, its                     SSN and CC:
          this
          stated on            o       Must use the term credit check and the customer must be aware and consent to the
          category                     credit check.

                               o       Must not read the entire SSN nor CC number aloud.
          the fraud
          policy for
          od the               o       Implied consent for the SSN and CC is permissible, but only at the point in the call where
          understo                     we are running a credit check or processing the CC. For example, “ May I have your
          clearly                      Social Security number in order to run a credit check?” When the customer provides
          dge that I                   their SSN this is implied consent to run the credit check.
          acknowle
          page, I              o       All other Line Item Definition specified under SSN and Credit Card Use that are non-
                                       fraudulent.



                                                                                                                                                                                                                                                    Fraud Management Process
          on this
          my initials
          signing
          By
                                                                                                 ACKNOWLEDGMENT
          e Initial] -
          [Employe
          _________        By signing this memorandum, I acknowledge having received a copy of this DIRECTV DS Red
          ___________      Alert Policy and Fraud Management Process document – The contents of which were
                           explained to me and which I fully understand and in conformity with.

                           Conforme:




                13 | P a g e
VXI Global – DIRECTV Red Alert Policy

______________________________________           __________________ ________________

DIRECTV – Assigned Employee Signature                   HRID                DATE
Over Printed Name


Discussed By:



______________________________________           __________________ ________________

DIRECTV – Assigned Employee Signature                Designation            DATE
Over Printed Name



          These policies are applicable to all DIRECTV –Assigned Employees who are taking
          phone calls, regardless of the position/designation.




                                                                                            Fraud Management Process




14 | P a g e

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Sample - Process Documentation

  • 1. DIRECTV DS Red Alert Policy Fraud Management Process Effective June 2010 DIRECTV Direct Sales The information covered in this policy includes, but not limited to, creating fraudulent transactions and activities, misleading customers, creating fraudulent sales, call avoidance, slamming, cramming, keeping/storing of VXI Global- QA Dept. customer’s confidential information and any acts of SM Cyber2 Jupiter and discourtesy. This policy covers all employees assigned to Zodiac Sts. Corner DIRECTV, regardless of position, directly or indirectly Buendia Ave., Makati involved in the transactions and activities. City Philippines 1226 + (632)899.2200 Fraud Management Process
  • 2. VXI Global – DIRECTV Red Alert Policy Policy Statement This policy shows the rules and guidelines formulated or adopted by DIRECTV as VXI Global account to reach its long-term goals. These principles are designed to influence and determine all major decisions and actions, and all activities take place within the boundaries set by them. The procedures provided are the specific methods employed to express policies in action in day-to-day operations of the organization. Together, policies and procedures ensure that a point of view held by the governing body of an organization is translated into steps that result in an outcome compatible with the view. Objectives  To inform DIRECTV – assigned employees of the QA Red Alert Policy. Red Alert Policies are at par with the VXI- Global Fraud Management Process and with the most updated DIRECTV Direct  To apprise DIRECTV – assigned employees Sales Quality Line Item Definitions – [Section 3.0 Standards | of the corresponding penalties for Legal Compliance] infractions of the QA Red Alert Policy. Sanctions are at par with client [DIRECTV] guidelines and  To prevent and manage integrity-related company COCD | CCC. incidents and fraudulent transactions. Implementing Guidelines 1. All DIRECTV – assigned employees will be made aware of the different issues that will fall under the Red Alert Policy during the Training period (for New Hires) and day/s before implementation for existing DIRECTV – assigned employees. 2. Any violation of the specified policies shall be subjected to sanction as defined. 3. Management reserves the right to place any employee who violates or is suspected to have committed any of the specified policies on OTP (Off-the-Phone). Concerned employee shall remain on Fraud Management Process standby while awaiting recommendation from concerned departments. Procedure 1. QA will track the sending of these email Alerts then follow up on them to ensure proper disciplines are adhered to and in line with the disciplinary structure stated. 2. The specified policies have been determined by DIRECTV and VXI Global to be Red Alert Auto Fails and the following disciplinary actions are to be followed in the steps laid out. 2.1. The QA Analyst | Verifier will identify a potentially fraudulent transaction or an integrity related issue. 2|Page
  • 3. VXI Global – DIRECTV Red Alert Policy 2.2. The QA2 Analyst will listen to the call for validation. 2.3. A 2nd QA2 Analyst may have to do a re-validation of the call. 2.4. The QA Manager validates the incident and categorizes the case into any of the 8 fraud buckets. 2.5. The QA Manager enters the incident into the VXI Global Fraud Tracker. 2.6. The QA Manager informs the Team Lead of the concerned Sales Consultant, including the Group Manager|Shift Manager, HR|LR and Business Leader about the incident. At the same time, the sales consultant will be advised by either the Team Lead or Workforce to be off the phones while the case is under investigation. 2.7. The case will be discussed within 24 hours and determines validity with Operations through a Call Listening session. 2.8. Once validated by both department (Quality Assurance and Operations), a mutual decision from department managers will be reached regarding the case and it’s sanction. An IR will be issued and the case will be forwarded to HR|LR for review and processing of necessary documents. IF BOTH DEPARTMENT MANAGERS DON ’ T AGREE WITH THE CASE AND SANCTIONS , THE CASE WILL BE ESCALATED TO LEVEL 2 FRAUD COMMITTEE (DIRECTOR LEVEL) AND CASE SHOULD BE AGREED UPON AND CLOSED OUT . FINAL DECISION AND SUPPORTING DOCUMENTATIONS SHOULD BE FORWARDED TO HR|LR WITHIN 24 HOURS FROM TIME OF ESCALATION . 3. Quality Assurance, Workforce Management, Operations and Human Resources Department shall ensure that necessary and pertinent documentation|reports|recordings|et.al. are completed and made Fraud Management Process available upon endorsement of the case. In cases of dismissal, HR established guidelines and processes should be followed. Administration Violation of this policy shall merit corresponding disciplinary action as defined under the COCD|CCC guidelines. The degree of sanction is dependent upon the offense’s classification. Details of the DIRECTV Red Alert Policy The Red Alert issue is categorized into any of the 8 fraud buckets set by VXI Global‘s Fraud Management Process and will be aligned if not mirrored from the DIRECTV Line Item Definition. 3|Page
  • 4. Fraud Category 1 – No Proof of Sale Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy EXAMPLES ARE BUT NOT LIMITED TO:  Creating fraudulent sales or found to be of no call/s based on CDR.  No matching orders found in OOM | OMS, RIO and other DIRECTV – VXI systems.  Absence of call recording in DRS and no CDR log entry. violated. when sanction and details scope, page, its this stated on category the fraud policy for od the understo clearly dge that I acknowle page, I on this my initials signing Fraud Management Process By e Initial] - [Employe _________ ___________ 4|Page
  • 5. Fraud Category 2 – Misleading the Customer Where the Information was Critical in Closing the Sale. Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy EXAMPLES ARE BUT NOT LIMITED TO:  Not disclosing the full amount to be charged to the customer’s card. Amount should be clearly explained and broken down [from equipment fees, customer fee based on credit check, taxes, etc.] to the customer.  Slurring. – The amount, legal disclosures [RCCs], pertinent information about the package the customer is getting should be clearly disclosed| discussed to the customer. Slurring means: install dates should details or delivery| be disclosed to the information which pertains to pricing o Not to enunciate words normally or clearly. and promotions o To pass over lightly or carelessly; treat customer. All critical violated. violated. without due consideration. when If the customer agrees at the time of sales call but when sanction upon investigation, customer ended up in sanction and cancelation of the service and complaint because and of the misunderstanding of the said disclosures [and matches the part of the call where the SC details details was observed to be slurring] – then the fraud case will be automatically valid. If there are no scope, scope, complaints logged in RIO or other DIRECTV-VXI tool at the time of investigation, then further page, its its page, investigations will be done. thisthis stated on on stated category category  Providing the customer with promotions | credits that are not supposed to be given or thethe fraud fraud combined. Examples are but not limited to: policy for for policy od od the the o Combining Referral credits with the Ambassador DNIS understo Taking email address of non-customer just to provide the extra $5 national offer rebate understo o clearly and/or not verifying full access to the email account. clearly dge that I I dge that acknowle acknowle o Soliciting ANY email addresses from the customer just to provide the extra $5 national page, I I page, offer rebate. on this on this my my initials initials  Guaranteeing the customer with the type and/or number of receivers, packages, promotions that are not matching with the order and policies. Fraud Management Process signing signing By By e Initial] - -  Informing the customer that they can call Customer Installation Support for sooner install dates or guaranteeing an installation date. e Initial] [Employe [Employe _________ _________  Telling the customer that they may or will get other promotional discounts after the 12 ___________ ___________ month promotional period [24 months for Enhanced markets] or advising the customer to call Customer care for existing offers after the 12/24 month period.  Signing the customer up to Preferred Choice and other small international package as an offer to a price point not to fit an international viewing need.  Placing the order through Western Union and leading the customer to believe that they have not placed an order. 5|Page
  • 6. Fraud Category 3 – No Agreement to Sale. Customer Didn’t Agree to Sale. Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy  Informing a customer that they should go to a retailer and purchase a prepaid card to secure their DIRECTV order. The only exception to this policy is if the customer has been educated on the Purchase Option as a prepaid card is a valid form of payment for the Purchase Option.  Selling to customers that are ineligible to new offers and/or to customers wherein call should have been transferred to another department. Examples [but not limited to] – Second account under the same account information, seasonal homes, etc. violated. sanction when details and page, its scope, stated on this fraud category the policy for the I clearly understood I acknowledge that initials on this page, By signing my [Employee Initial] - Fraud Management Process ____________________ EXAMPLES ARE BUT NOT LIMITED TO:  SC charging the customer’s credit |debit card without authorization. This includes charging the customer’s card after stating that there are no funds or enough funds to cover the amount disclosed. The only exception is if the customer proactively told the SC to try and charge the card despite the lack of funds.  Double | Multiple tagging of Sales in CRM |OOM. 6|Page
  • 7. Fraud Category 4 – Out of Process [Internal] Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy  Customer stated to cancel the order and the SC failed to cancel the order– whether the call got disconnected or not.  Customer stated to cancel the order and the SC canceled the order in OOM but still tagged the order as a sale in CRM.  For MA|PA orders, the call should be done up to the giving of the account number and Western Union details with instructions to the customer for it to be considered as a sale. If the call gets disconnected prior to this, the SC is expected to cancel the order in OOM and tag it as a non-sale in CRM. This covers VXI Global’s Internal Procedures that are directly impacting customer’s information security, violation of company policies that are affecting the set SLA’s and some other processes that were mandated by DIRECTV. EXAMPLES ARE BUT NOT LIMITED TO: Fraud Management Process  Storing or saving of customer information [i.e. credit | debit card number, SSN etc. al.] on paper or any tools other than those stipulated by management. Said information MUST BE DELETED after every call is made. o This includes usage of other computer notepads other than what was authorized and approved by VXI Global. [Notepad from DTV Links – 100 character limit]  Call Avoidance – is any action where any employee takes action to avoid taking calls. Examples are but not limited to: o Placing customer on long hold | mute for no valid reason just to elongate the call. o Placing customer on long hold | mute until the customer hang –up. o Hanging up on calls while engaged with a customer. 7|Page
  • 8. Fraud Category 5 – Unauthorized Use of Customer Credit Card, SSN and other Personal Information Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy o Telling the customer that he|she is still waiting for the system to upload before she|he can set up the install date or provide the account number when on the DRS screen, it’s already showing the said information.  Call back Policy - Once the SC have read the RCCs and processed the credit card (with customer permission), it is considered a SALE. o If the call drops after this point, agents should flag their Team Manager immediately. o Team Manager will have the authority to call the customer back to complete the installation portion of order. o If the call gets disconnected and the SC has not read the RCCs and processed the credit card yet then this is not a sale and NO callback should be made. violated. when sanction and details scope, page, its EXAMPLES ARE BUT NOT LIMITED TO: this stated on category the fraud  Using other CC or SSN not given by the customer just to process a sale. policy for od the  Alteration of customer’s personal information. understo  Illegal use of customer’s credit card. clearly dge that I  Knowingly setting up service in the name of someone other than the person being acknowle spoken to. page, I on this  The SC must request and receive verbal authorization to do a credit check before the my initials credit check is performed. Fraud Management Process signing  The SC must get verbal authorization from the CC holder other than the person being By spoken to. Note: Only if using the SPOUSE’S Card. Even if the card is from a joint e Initial] - account, the name of the customer the SC is speaking to should be the name that [Employe appears on the card. _________ ___________  Credit being ran by sales consultant on address without the knowledge of the customer or without requesting for SSN. Customer must be aware of how the credit check is being run. i.e. SSN, ITIN or address.  SSN and Payment authorization override. 8|Page
  • 9. Fraud Category 6 – Misrepresenting Sales Consultant’s Identity and Company’s Credibility Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy violated. violated. when when sanction sanction and and details details scope, EXAMPLES ARE BUT NOT LIMITED TO: scope, its page, page, its  SC changing his|her job title over the phone to gain authority or for whatever the purpose may this this be. stated on stated on category category the fraud  Co-Sales Consultant taking over another SC’s call without authorization from the Team Lead, the fraud policy for GM, OM or BL [Management]. policy for od the od the understo o POC for the day is not considered part of management which means a POC cannot understo clearly delegate nor ask another SC to take over someone’s call. clearly  SC was found to have done any act/s of discourtesy. Examples are but not limited to: dge that I dge that I acknowle acknowle page, I o Usage of profanity [whether in English or any other language] and argumentative tone. page, I on this on this my initials o Sarcastic and sexual remarks | comments while engaged or on-hold with the customer. my initials signing signing By Fraud Management Process By Initial] - e e [Employe Initial] - [Employe _________ _________ ___________ ___________ 9|Page
  • 10. Fraud Category 7 – Unauthorized Data Entry | Modifications [System Manipulation] Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy EXAMPLES ARE BUT NOT LIMITED TO:  Attempting to cancel existing order|account. violated. when sanction  Changing DNIS call source. and details  MA|PA – Western Union Manipulation. Examples are but not limited to: scope, page, its o Changing a zip code to a Massachusetts or Pennsylvania zip code to pop the Western this Union option whether the customer has a credit card or not. stated on o Changing the address of the customer to a MA|PA address not provided by the category customer. the fraud policy for  Information entered in OOM | CRM weren’t given by the customer. This includes interchanging od the of customer details. Example: Phone number provided by the understo System Manipulation which customer and was heard on the call: (123) 456.7890 and the clearly leads to Sales Consultant’s SC typed (132) 456.7890 dge that I Financial Benefit [SPIFFs,  Any manipulation of OOM or CRM in order to achieve a sale. acknowle Bonuses, Commissions and page, I other incentives – whether Proactively processing a referral credit from an existing  on this customer calling on behalf of a new customer on a non- DIRECTV or VXI Global my initials referral DNIS and the existing customer not specifying that signing initiated] he|she has been referred. [The word “REFERRED” should be By said or mentioned by the customer]. Fraud Management Process e Initial] - [Employe  Bypassing any system blocks or pop ups to try and process a sale. Examples are but not limited _________ to: ___________ o Proactively asking for an alternate phone number from a customer to bypass the system block. o Proactively requesting another person’s credit card or SSN to set up an account other than who is on the phone [not unless customer initiated] and making use of Canadian SSN to run a credit check  Accessing another website which can provide other customer information matching some of those that were provided by the customer on the phone. Example is but not limited to: Accessing www.whitepages.com and typing customer’s name [John Doe] and trying different addresses from the results of the search. 10 | P a g e
  • 11. VXI Global – DIRECTV Red Alert Policy o Only exception is www.USPS.com when the customer is claiming they don’t know the ZIP CODE to the service address.  Making changes on the customer information. [CRM vs. OOM and other systems] Examples are but not limited to: o Changing the information on CRM after OOM was released. The information in CRM should ALWAYS match the information in OOM or vice versa. o Changing the customer information after running the credit check. violated. when sanction and details scope, page, its this stated on category the fraud policy for od the understo clearly dge that I acknowle page, I on this my initials signing By e Initial] - [Employe _________ Fraud Management Process ___________ 11 | P a g e
  • 12. Fraud Category 8 – Client Escalations Sanction: Termination of Employment VXI Global – DIRECTV Red Alert Policy EXAMPLES ARE BUT NOT LIMITED TO:  Valid Customer | client complaint. [Complaints already violated by both QA and client].  This includes client – initiated removal. violated. when sanction details and scope, page, its stated on this category the fraud the policy for understood that I clearly acknowledge page, I initials on this signing my Fraud Management Process Initial] - By [Employee _____ _______________ EXAMPLES ARE BUT NOT LIMITED TO:  Required Call Components | Inaccurate Information: 12 | P a g e
  • 13. Any Other Auto-Fails Not Classified as Fraud Sanction: Progressive VXI Global – DIRECTV Red Alert Policy o Local channels must be addressed at the beginning or during RCC. Should not read all channels available. Should cover what is not available specifically. Mention HD if applicable. o All other Line Item Definition specified under RCCs and Accurate Information that are [OR as stated in the COCD/CCC] 1st in 90 days – Verbal Warning occurrence –Written Warning occurrence – Termination of 2nd in 90 days from the first 3rd in 90 days from the first 4th in 90 days from the first occurrence – Final Written Employment Sanctions: violated. Warning when sanction and non-fraudulent. details scope, page, its  SSN and CC: this stated on o Must use the term credit check and the customer must be aware and consent to the category credit check. o Must not read the entire SSN nor CC number aloud. the fraud policy for od the o Implied consent for the SSN and CC is permissible, but only at the point in the call where understo we are running a credit check or processing the CC. For example, “ May I have your clearly Social Security number in order to run a credit check?” When the customer provides dge that I their SSN this is implied consent to run the credit check. acknowle page, I o All other Line Item Definition specified under SSN and Credit Card Use that are non- fraudulent. Fraud Management Process on this my initials signing By ACKNOWLEDGMENT e Initial] - [Employe _________ By signing this memorandum, I acknowledge having received a copy of this DIRECTV DS Red ___________ Alert Policy and Fraud Management Process document – The contents of which were explained to me and which I fully understand and in conformity with. Conforme: 13 | P a g e
  • 14. VXI Global – DIRECTV Red Alert Policy ______________________________________ __________________ ________________ DIRECTV – Assigned Employee Signature HRID DATE Over Printed Name Discussed By: ______________________________________ __________________ ________________ DIRECTV – Assigned Employee Signature Designation DATE Over Printed Name These policies are applicable to all DIRECTV –Assigned Employees who are taking phone calls, regardless of the position/designation. Fraud Management Process 14 | P a g e