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ACKNOWLEDGE & EXECUTE THE INTERNAL COMPLIANCE MEMO

FOR: All Independent Sales Representatives, Employees, and Authorized Agents

FROM: Compliance & Operations — Create Telecom LLC

DATE: June 28, 2026  |  SUBJECT: Platform Compliance, Conduct Standards & Commission Rules

This Internal Compliance Memo establishes the mandatory conduct standards, commission rules, data boundaries, and regulatory requirements for all personnel operating under or in association with Create Telecom LLC (d/b/a Ready Freddy). This document supplements — and does not replace — the Independent Sales Representative Agreement, Master Terms of Service, and Privacy Policy. All personnel are expected to read, understand, and comply with this memo in full.

Violation of any rule in this memo may result in immediate termination of your engagement, forfeiture of earned commissions, and referral to the appropriate regulatory authority.

SECTION 1: WHO THIS MEMO COVERS

This memo applies to:

• Independent Sales Representatives (1099 contractors) operating under a signed Independent Sales Representative Agreement;
• Employees and internal team members with access to the platform dashboard, CRM data, or client accounts;
• Any authorized agent, reseller, or white-label partner operating on behalf of Create Telecom LLC.

Throughout this memo, the term “Agent” refers to all of the above categories unless otherwise specified.

SECTION 2: INDEPENDENT CONTRACTOR STATUS — IRS AND TAX RULES

2.1 You Are Not an Employee. All sales representatives operate as independent contractors under IRS classification guidelines. This means:

• Create Telecom LLC does not withhold federal or state income taxes from your commission payments.
• Create Telecom LLC does not pay Social Security, Medicare (FICA), or unemployment (FUTA) taxes on your behalf.
• You are solely responsible for paying self-employment tax (currently 15.3% on net self-employment income up to the annual threshold) and quarterly estimated income taxes.
• You are not entitled to employee benefits including health insurance, retirement contributions, paid leave, or workers' compensation.

2.2 Your Tax Documentation Requirements. Before you receive your first commission payment, you must:

• Submit a completed IRS Form W-9 through the Stripe Connect Express onboarding portal. We do not collect or store your SSN or EIN — this information goes directly to Stripe's encrypted vault.
• Ensure your Stripe Connect Express account is active and in good standing. We cannot process payouts to invalid or incomplete accounts.
• Maintain your own records of all income received for your annual tax filing.

2.3 IRS Form 1099-NEC. If your total commission payments from Create Telecom LLC in a calendar year equal or exceed $600, we will issue an IRS Form 1099-NEC to you no later than January 31 of the following year. You are responsible for reporting all income received, including amounts below the $600 reporting threshold.

2.4 No Employer-Employee Relationship. You agree not to represent yourself as an employee of Create Telecom LLC to any client, prospect, tax authority, or third party. You retain full discretion over your own working hours, sales methods, and tools — provided your activities comply with this memo and your Contractor Agreement.

SECTION 3: COMMISSION STRUCTURE AND PAYMENT RULES

3.1 How You Earn. You earn commissions on the monthly recurring revenue (MRR) generated by each client you successfully onboard using your unique tracking link (?ref=PARTNER-XXXX) or assigned QR code. A client is “successfully onboarded” when:

• The client registers for a paid subscription through your Referral Identifier;
• The client's first subscription payment clears without dispute; and
• No chargeback, refund, or fraud flag is raised within thirty (30) days of payment.

3.2 Commission Rate Schedule.

• One-Time Setup Fee: 20% of Cleared Fee (Earn $100 on Starter, $200 on Growth, $400 on Pro)
• Subscription Months 1–12: 20% of MRR (Introductory monthly residual rate)
• Month 13 Onward: 10% of MRR (Permanent lifestyle maintenance residual)

3.3 What Counts as MRR. Commissionable Revenue includes the monthly recurring subscription fee (MRR) and the one-time upfront setup fee collected from the client, excluding taxes, refunds, chargebacks, and payment processing fees. You do not earn commission on: (a) months in which the client's account is suspended, past-due, cancelled, or inactive; or (c) amounts reversed via chargeback after payment.

3.4 Payout Schedule. Commissions are calculated on a trailing monthly basis and paid via Stripe Connect no later than thirty (30) calendar days after the end of the month in which the revenue was collected and cleared. You are responsible for maintaining an active Stripe Connect Express account. Delays caused by your invalid or incomplete account are not the Company's liability. Setup fee allocations are disbursed in the standard monthly trailing payout cycle immediately following the 30-day risk clearing window after successful expiration and collection of the 14-day free trial invoice (totaling approximately 44 days from initial client registration).

3.5 Clawback Policy. If a commission is paid on a transaction that is subsequently reversed via chargeback, refund, or fraud determination, the Company reserves the right to deduct the previously paid commission from your future payouts.

3.6 Dispute Resolution for Commission Errors. If you believe your commission was calculated incorrectly, you must submit a written dispute to the Company within sixty (60) days of the disputed payout date. Failure to dispute within this window constitutes acceptance of the payout as final.

SECTION 4: WHAT YOU MAY AND MAY NOT DO — CONDUCT RULES

4.1 Permitted Activities.

• Sharing your unique referral link (?ref=PARTNER-XXXX) or QR code with prospective clients via personal outreach, social media, email, or in-person sales.
• Using Company-approved marketing materials to promote the Platform's features and benefits.
• Conducting demos or walkthroughs of the Platform's publicly disclosed features to qualified prospects.
• Answering prospect questions about pricing tiers, subscription features, and setup process based on accurate, current information from the Company.

4.2 Strictly Prohibited Activities. The following are absolute violations and may result in immediate termination and forfeiture of all future residuals:

• Spam and Unsolicited Messages. Sending bulk unsolicited emails or text messages using the Company's brand, name, or referral identifiers in violation of the CAN-SPAM Act or TCPA. You are personally liable for any compliance violations arising from your outreach.
• Misrepresentation. Overstating, fabricating, or misrepresenting the features, capabilities, pricing, integrations, guarantees, or results of the Platform to any prospect or client.
• Price Manipulation. Quoting prices, discounts, or deal terms that differ from the Company's published pricing without written authorization from the Company.
• Reverse Engineering. Attempting to decompile, disassemble, or otherwise derive the source code, prompt routing logic, AI training weights, or proprietary algorithms of the Ready Freddy platform.
• Data Circumvention. Accessing, exporting, copying, or using client CRM data outside the Platform's authorized systems, or directing clients to pay you directly to bypass the Company's payment processing system.
• Unauthorized IP Use. Using the Company's trademarks, logos, brand name, or marketing assets in any format not expressly approved in writing by the Company.
• False Claims of Employment. Representing yourself as an employee, officer, partner, or owner of Create Telecom LLC to any person or entity.
• Competing Platform Referrals. Simultaneously referring clients to a directly competing AI chatbot or automated lead-capture platform without prior written consent from the Company.

SECTION 5: DATA BOUNDARIES — WHAT YOU CAN AND CANNOT SEE

Your role as a sales agent grants you access to your own performance dashboard only. This means:

• You can see: your referral tracking link, your total referral count, your commission totals, your payout history, and the subscription tier of clients you referred (for commission calculation purposes only).
• You cannot see: individual client CRM records, lead lists, conversation transcripts, End User contact information, or any data inside a subscriber’s platform account.
• You must not attempt to access client data beyond what is visible in your partner dashboard. Any such attempt constitutes a material breach and will result in immediate termination.

These boundaries exist to protect client privacy, comply with applicable privacy laws, and maintain the trust of our subscriber base. Violations will be treated as serious misconduct.

SECTION 6: REGULATORY COMPLIANCE — YOUR PERSONAL OBLIGATIONS

6.1 TCPA and CAN-SPAM. If you send any automated or bulk communications to prospects using the Company's brand or referral link, you are personally responsible for compliance with:

• The Telephone Consumer Protection Act (TCPA) — you must have prior express written consent before sending automated text messages or calls.
• The CAN-SPAM Act — all commercial emails must include accurate sender information, a non-deceptive subject line, your physical address, and a functioning unsubscribe mechanism.
• The FTC Act — you must not make false or misleading claims about the Platform in any marketing materials.

6.2 AI and Disclosure Requirements. If you conduct demos or presentations that use the Platform’s AI voice or chat features, you must accurately disclose that these features are AI-powered and automated. You may not represent AI-generated outputs as the result of human review or activity unless that is true.

6.3 FTC Endorsement Guidelines. If you post testimonials, case studies, or results-based claims about the Platform on social media or in marketing materials, you must clearly disclose your material connection to Create Telecom LLC (i.e., that you earn commissions for referrals). This is a requirement under FTC Endorsement Guidelines, 16 C.F.R. Part 255. Example acceptable disclosure: “I'm a paid affiliate for Ready Freddy and may earn a commission if you sign up through my link.”

SECTION 7: TERMINATION OF YOUR ENGAGEMENT

7.1 Termination Without Cause. Either you or the Company may end this engagement at any time with thirty (30) days' written notice. If terminated without cause, you will continue to receive commissions on your active client accounts for ninety (90) days after the termination date, after which all commission obligations cease.

7.2 Termination for Cause. The Company may terminate your engagement immediately, without notice or severance, if you:

• Violate any provision of Section 4.2 (Prohibited Activities);
• Commit fraud, misrepresentation, or willful misconduct;
• Violate any TCPA, CAN-SPAM, or FTC regulation in connection with your promotion of the Platform;
• Attempt to circumvent the Company’s payment or data systems.

Termination for cause results in the immediate and permanent forfeiture of all future residual commission payments, with no further obligation by the Company.

7.3 Post-Termination Obligations. Upon termination for any reason, you must:

• Immediately cease using the Company’s trademarks, brand assets, and referral link in any new outreach;
• Remove or update any existing marketing materials that reference Create Telecom LLC or Ready Freddy;
• Return or destroy any Confidential Information of the Company in your possession.

SECTION 8: CONFIDENTIALITY

During your engagement and for three (3) years after termination, you agree to keep strictly confidential all non-public information you learn about Create Telecom LLC, including: pricing structures, client lists, technical architecture, commission formulas, platform roadmap, and business strategies. You may not share this information with competitors, prospective employers, or the general public.

A violation of this confidentiality obligation may cause irreparable harm to the Company, entitling the Company to seek immediate injunctive relief in addition to any other remedies available by law.

SECTION 9: ACKNOWLEDGMENT AND CERTIFICATION

By electronically executing this memo below, you certify that:

• You have read and fully understand this Internal Compliance Memo;
• You agree to comply with all rules, standards, and obligations described herein;
• You understand that violations may result in immediate termination and forfeiture of commissions;
• You have been given the opportunity to ask questions and seek legal advice before signing;
• You will complete IRS Form W-9 through Stripe Connect Express before receiving any commission payment.

Create Telecom LLC  |  961 Almaden Street, Eugene, OR 97402  |  [email protected]  |  https://createtelecom.net

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