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Revision date: February 27, 2018

Preamble

Hispano Club’s (“Hispano Club” or the “Company”) Code of Ethics is to ensure the protection towards consumers/clients from deceptive or misleading treatment arising out of the personal-contact method of distribution of our products and or services. The Company hereby sets forth the basic fair and ethical principles and practices to which each Independent Sales Associate (“Associate”) of Hispano Club must continuously adhere to while promoting its independent business membership of Hispano Club.

  1. Deceptive or Unlawful Sales or Recruiting Practices
    1. No Associate shall engage in any deceptive, false, unethical or unlawful sales or recruiting practice. Each Associate shall ensure that no statements, promises or testimonials are made that are misleading or that are likely to mislead consumers or prospective Associates.
    2. All Associates shall comply with these requirements to ensure their continuing eligibility in the Hispano Club multilevel marketing program.
    3. Information provided by Associates to prospective or current Associates concerning the independent business opportunity and related rights and obligations shall be accurate and complete. Associates shall not make any factual representation to prospective Associates that cannot be verified or make any promise that cannot be fulfilled.
    4. Associates shall not present any selling opportunity to any prospective Associate in a false, deceptive or misleading manner.
    5. Associates shall not induce a person to purchase products or services based upon the representation that a consumer can recover all or part of the purchase price by referring other prospective Associates.
    6. Associates shall respect any lack of commercial experience of consumers. Associates shall not abuse the trust of individual consumers, or exploit a consumer’s age, illness, handicap, lack of understanding or unfamiliarity with a language.
  2. Services and Promotional Materials
    1. The offering of products or services for sale by the Associates shall be accurate and truthful as to price, grade, quality, make, value, performance, quantity, ease of use, and availability. All product or service claims made by the Associates must be substantiated by competent and reliable evidence and must not be misleading. A consumer’s order of products and services shall be fulfilled in a timely manner.
    2. The Associates shall not make misleading comparisons of another company’s direct selling opportunity, products or services. The Associates shall not denigrate any other company, business, product or service directly or by implication in a false or misleading manner and shall not take unfair advantage of the goodwill attached to the trade name and symbol of any company, business, product or service.
    3. Promotional literature, advertising and mailings shall not contain product descriptions, claims, photos or illustrations that are false, deceptive or misleading.
    4. Associates shall offer consumers accurate information regarding: price; terms of payment; a cooling-off period; return policies; terms of guarantee; after-sales service; and delivery dates. Associates shall give accurate answers to questions from consumers.
  3. Terms of Sale
    1. A written order or receipt shall be delivered to the consumer concurrently with the initial sale. In the case of a sale made through the mail, telephone, internet, or other non-face-to-face means, a copy of the order form shall have been previously provided, shall be included in the initial order, or will be provided in printable or downloadable form through the internet. The order form must be written clearly, legibly and unambiguously.
    2. Terms and conditions of sale, including the total amount the consumer will be required to pay, including all interest, service charges and fees, and other costs and expenses as required by federal and state law, will be clearly articulated in the final sale materials and order.
    3. The Associate must provide the full name, permanent address and telephone number of the business the Associate is representing.
  4. Warranties
    1. Terms of warranty, details and any limitations of after-sales service, name and address of any guarantor or warrantor, length of the warranty and the remedial action available to the consumer shall be fully made available to the consumer. Alternatively, this information may be provided with other accompanying literature provided with the product or service.
    2. Hispano Club shall offer a clearly stated written cooling-off period permitting the consumer to withdraw from a purchase order within a minimum of thirty days from the date of the purchase transaction and receive a full refund of the purchase price, minus a processing fee, which will depend on the state where the sale was made. In addition, Hispano Club may offset from such refund any telemedicine consultations or roadside assistance utilized during the such 30 days.
    3. If the consumer paid his or her Hispano Club® Membership in a single payment and decides to cancel his or her Hispano Club® Membership after the cooling-off Period, the customer will receive a pro-rata refund, less a nominal processing fee, which will depend on the state where the sale was made.
  5. Identification and Privacy
    1. At the beginning of a sales presentation, the Associates shall truthfully and clearly identify themselves, the Company and the nature of the Company’s products or services and the reason for the solicitation. Contact with the consumer shall be made in a polite manner and during reasonable hours. A demonstration or sales presentation shall stop upon the consumer’s request.
    2. All private consumer information shall be safe-guarded properly for the protection of all private information provided by a consumer, Associate or prospective Associate.
  6. Pyramid Schemes
    1. Pyramid schemes are illegal and, among other things, involves misleading recruitment undertaken by an Associate or others acting with or for the Associate, and that involves direct or indirect promises of false income expectations and expectations of business development that are unrealistic or not achievable. The Associate should seek counsel from the appropriate personnel of the Company to ensure that it does not unwittingly or intentionally engage in pyramid type promotional efforts, often also referred to as endless chain schemes. Any such efforts, intentional or otherwise, shall be considered actionable for termination of the Associate.
  7. Inventory Purchases
    1. Hispano Club is a services company that requires no inventory. Each product or service that the Associate sells shall be of record to a registered individual or end-user consumer.
  8. Earnings Representations
    1. Misrepresentations include any oral, written or visual claim that conveys, expressly or by implication, a specific level or range of actual or potential sales or gross or net income or profits, including, but not limited to, representations that either explicitly or implicitly suggest that lifestyle purchases, including homes, vehicles, vacations and the like, are related to or obtainable through anticipated income earned. It is forbidden to use projections of future income earnable or expectable not authorized by the Company. The Company only condones the diligent operation of a lawful business by and Associate, hard work, and lawful efforts at selling products or services.
    2. Any statement, representation or hypothetical scenario from which a prospective independent sales person or Associate could reasonably infer that he or she will earn a minimum level of income constitutes a misrepresentation.
    3. Any chart, table or mathematical calculation demonstrating possible income, actual or potential sales, or gross or net profits based upon a combination of variables is not permitted and considered a misrepresentation.
    4. Marketing materials or advertising explicitly describing or promising potential income or the ability to acquire or afford material goods or improved lifestyles is considered a misrepresentation and not permitted.
    5. To the extent of any approved discussions regarding potential earnings and sales potentials of prospective Associates must be provided with sufficient qualifications and other balanced information to ensure that the recipient understands that:
      • Actual earnings can vary significantly depending upon time committed, skill level and other factors.
      • Not everyone will achieve any hypothetical level of income and such amounts are before expenses and personal labor, if any.
      • Current and prospective Associates must be provided with sufficient information to enable a reasonable evaluation of the opportunity to earn income.
      • Any sales earnings representations must be documented and substantiated based on actual and proven experiences. Associates must maintain such documentation and substantiation, making it available to the Hispano Club upon written request.
  9. Payment and Fees
    1. Associates shall follow all the rules in accordance with charging the proper fees assigned by Hispano Club as to the cost of the business kit or membership services. No unreasonable extra fees shall be collected by the Associates that are not officially stated or approved by the Company.
  10. Training and Materials
    1. Hispano Club shall provide adequate training to enable Associates to operate ethically. Such trainings will include the scope of permissible representations especially in the parameters regarding product claims and earnings.
  11. Idiomas
    1. Este Código se redactó tanto en inglés como en español. En caso de que exista alguna inconsistencia, prevalecerá la versión en inglés y la misma será vinculante para las partes.

DISCLOSURES FOR DISCOUNT DENTAL, VISION, LAB AND DIAGNOSTIC IMAGING: These discounts are not available in AK, OK, UT, VT and WA. The discount medical benefits (“The Plan”) are NOT insurance, a health insurance policy or a qualified health plan under the Affordable Care Act. The Plan provides discounts at certain health care providers for medical services or products. The range of discounts will vary depending on the type of provider and service received. The Plan does not make and is prohibited from making members’ payments to providers for medical services or products received under the Plan. The Plan member is required and obligated to pay for the entire discounted rate for the medical services or products but will receive a discount from those health care providers who have contracted with the discount medical plan organization. The Discount Medical Plan/Discount Plan Organization is Alliance HealthCard of Florida, Inc., 2711 North Haskell Avenue, Suite 800, Dallas, TX 75204. You may call 800-565-3827 for more information or visit www.HispanoClub.com to locate participating providers. The Plan will make available before purchase and upon request, a list of program providers and the providers’ city, state and specialty, located in the member’s service area. Alliance HealthCard of Florida, Inc. does not guarantee the quality of the services or products offered by individual providers. Any complaints should be directed to Alliance HealthCard of Florida, Inc. at the address or phone number above. Upon receipt of the complaint, member will receive confirmation of receipt within 5 business days. After investigation of the complaint, Alliance HealthCard of Florida, Inc. will provide member with the results and a proposed resolution no later than 30 days after receipt of the complaint. Note to DE, IL, LA, NE, NH, OH, RI, SD, TX, and WV consumers: If you remain dissatisfied after completing the complaint system, you may contact your state department of insurance. Note to MA consumers: The Plan is not insurance coverage and does not meet the minimum creditable coverage requirements under M.G.L. c. 111M and 956 CMR 5.00.




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