Updated in 2013 Operating Procedures for Compliance with CPNI Rules Hamilton elephone Compan!

"I#$ %01&1'( Hamilton )ong #istance Compan! "I#$ %01&1*( Hamilton elephone Compan! and Hamilton )ong #istance Compan! "hereinafter +Hamilton,( ha-e implemented the following procedures to ensure compliance with Part *. of itle ./ of the Code of 0ederal Regulations1 2u3part U 4 Customer Proprietar! Networ5 Information "CPNI(1 *.62001 through *.620116 he purpose of these procedures is to safeguard customer information6 Compliance Officer Hamilton has appointed a CPNI Compliance Officer and a 3ac57up Compliance Officer6 he Compliance Officer is responsi3le for ensuring that Hamilton is in compliance with all of the CPNI rules6 he Compliance Officer is also the point of contact for an!one "internall! or e8ternall!( with 9uestions a3out CPNI6 he 3ac57up Compliance Officer will follow all Operating Procedures in the a3sence of the Compliance Officer6 :mplo!ee raining CPNI regulator! training is re9uired for mar5eting personnel and Hamilton;s personnel who interact with customers and customer accounts6 :mplo!ees are trained on an annual 3asis and more fre9uentl! if needed6 Newl! hired emplo!ees are assessed to determine if CPNI training is applica3le6 If so the! will recei-e the proper training as re9uired 3! Hamilton;s polic!6 he training includes1 3ut is not limited to1 when emplo!ees are and are not authori<ed to use CPNI1 and on the authentication methods that Hamilton is using6 he detail of the training can differ 3ased on whether or not the emplo!ee has access to CPNI6 717

=fter completing this training1 all emplo!ees for whom this training is re9uired are also re9uired to sign a certification that the! ha-e recei-ed training on the CPNI rules1 that the! understand Hamilton;s procedures for protecting CPNI and the! understand Hamilton;s disciplinar! process for improper use of CPNI6 = CPNI manual that includes the rules is a-aila3le at each emplo!ee;s location6 =ll emplo!ees e8posed to CPNI ha-e 3een instructed that if the! ha-e an! 9uestions regarding the proper use of CPNI1 or if the! are aware of CPNI 3eing used improperl! 3! an!one1 the! should contact the Compliance Officer immediatel!6 Customer Notification and Re9uest for =ppro-al to Use CPNI Hamilton has pro-ided notification to its customers of their CPNI rights and has as5ed for the customer;s appro-al to use CPNI -ia the opt7out method6 = cop! of the notification is also pro-ided to all new customers that sign up for ser-ice6 he status of a customer;s CPNI appro-al is prominentl! displa!ed as soon as the customer;s account is accessed so that emplo!ees can readil! identif! customers that ha-e restricted the use of their CPNI6 0or the customers that ha-e opted7out and said that Hamilton cannot use their CPNI1 that decision will remain -alid until the customer changes it6 Hamilton will send the opt7out notice e-er! two !ears to those customers that ha-e not pre-iousl! opted out6 Hamilton does not share CPNI with an! >oint -enture partner1 independent contractor or an! third part!6 Hamilton will pro-ide written notice within fi-e 3usiness da!s to the 0CC of an! instance where the opt7out mechanisms do not wor5 properl!1 to such a degree that consumers; ina3ilit! to opt7out is more than an anomal!6 = cop! of the most recent notification is 5ept in the CPNI official files6 727

?ar5eting Campaigns he Compan! has esta3lished a super-isor! re-iew process for an! out3ound mar5eting that it does6 he Compliance Officer must re-iew all mar5eting campaigns to ensure that materials are in compliance with the CPNI rules6 he campaign must 3e appro-ed 3! the Compliance Officer6 he Compan! has a process for maintaining a record of an! mar5eting campaign of its own1 or its affiliates1 which uses CPNI6 he record will include a description of the campaign1 the specific CPNI that was used in the campaign and what products and ser-ices were offered as part of the campaign6 he record is 5ept for a minimum of one !ear6 Customer =uthentication Process Hamilton does not disclose an! CPNI until the customer has 3een appropriatel! authenticated as follows$ In-office visit the customer1 or an indi-idual that has 3een authori<ed 3! the customer to access the account1 must pro-ide a -alid photo I#6 Telephone inquiry the customer1 or an indi-idual that has 3een authori<ed 3! the customer to access the account1 is authenticated 3! pro-iding the esta3lished answer to our 9uestion for that specific account6 If a customer calls and the answer to our authentication 9uestion has not 3een esta3lished1 a Hamilton emplo!ee will contact the customer6 he emplo!ee will do this 3! calling the customer;s telephone num3er of record1 mailing the customer at their address of record or as5 the customer to come into the office with a -alid photo I# to esta3lish the answer to our authentication 9uestion6 Hamilton has not esta3lished a +password@ for pro-iding call7detail to its customers6 = re9uest for call7detail is handled as follows$ If the customer can pro-ide all of the call detail information "telephone num3er called1 when it was called1 the amount of the call1 etc6( necessar! to address the customer;s issue1 Hamilton will continue with its routine customer care procedures6 737

 If the customer cannot pro-ide all of the call detail information to address the customer;s issue1 Hamilton will$ "1( call the customer 3ac5 at the telephone num3er of record1 "2( send the information to the address of record1 or "3( as5 the customer to come into the office and pro-ide a -alid photo I#6 Customer Notification of =ccount Changes Hamilton notifies customers of an! changes that ha-e 3een made to their account1 either 3! sending a notification to the address of record or 3! calling the telephone num3er of record6 If the customer did not authori<e an! change1 the! are as5ed to contact our office immediatel!6 #isciplinar! Process Hamilton has esta3lished a specific disciplinar! process for improper use of CPNI6 he disciplinar! action is 3ased on the t!pe and se-erit! of the -iolation6 =ll -iolations will include retraining the emplo!ee on the CPNI rules6 =dditional disciplinar! action could include an! or all of the following$ ma5ing a notation in the emplo!ee;s personnel file1 a formal written reprimand1 suspension or termination6 = single incidence of an unintentional -iolation could 3e cause for the least se-ere discipline while intentional andAor multiple -iolations could 3e cause for the most se-ere discipline6 he disciplinar! process is included in the emplo!ee hand3oo5 under CPNI regulations6 It has 3een re-iewed with each emplo!ee that wor5s with CPNI6

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Notification of Breaches = 3reach occurs when a person1 without authori<ation or e8ceeding authori<ation1 has intentionall! gained access to1 used1 or disclosed CPNI with an intent to cause harm6 :mplo!ees will immediatel! notif! the Compliance Officer of an! indication of a 3reach6 If it is determined that a 3reach has occurred1 the Compliance Officer will do the following$ 16 Notif! the United 2tates 2ecret 2er-ice "U222( and the 0ederal Bureau of In-estigation "0BI( as soon as possi3le1 3ut not later than / 3usiness da!s after determination of the 3reach -ia their electronic lin5 at http$AAwww6fccAgo-Ae3Acpni6 26 Notif! the customer onl! after / 3usiness da!s ha-e passed since notification to the U222 and 0BI1 unless the U222 or 0BI has re9uested an e8tension6 36 ?aintain a record of the 3reach1 the notifications made to the U222 and 0BI and the notifications made to the customer6 = detailed description of CPNI that was the su3>ect of the 3reach1 dates the! ccurred1 how the 3reach occurred1 impact of the 3reach1 proof of notification to law enforcement and other pertinent details will need to 3e 5ept6 .6 =ll records will 3e maintained for 2 !ears and e8plained in the annual certification6 ?iscellaneous Hamilton;s CPNI policies include reasona3le measures to disco-er and protect against acti-it! that is indicati-e of prete8ting as well as an! other unauthori<ed attempts to access CPNI6 :mplo!ees are instructed to notif! the CPNI Compliance Officer of an! suspicious acti-it!6 he Compliance Officer will determine what action needs to 3e ta5en6 7'7

=nnual Certification he Compliance Officer will file a Compliance Certification with the 0CC 3! ?arch 1 of each !ear for data pertaining to the pre-ious calendar !ear6

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