Conflict Policy

At SOHO Prospecting we take seriously our ethical responsibilities and, in particular, where those responsibilities impact our clients’ competitiveness. There can be an inherent conflict between those responsibilities and the responsibility to provide profitability to our stakeholders.

When evaluating prospective business with companies that compete with current clients, we believe that we are required to avoid situations that may put one at an advantage over the other as a result of our work. On the other hand, we do not believe that we are required to turn away business that involves the provision of services to a new client that are not also provided to the current client or do not provide a strategic advantage of one over the other.

To further clarify this, our policy on clients that compete is as follows:

This conflict policy is adopted in every Internet Marketing Promotion and Advertising as well as printing / media services provided by SOHO Prospecting. Whether the marketing service is for small companies, start-up or large corporations, SOHO Prospecting is committed to you through this conflict policy.

Definitions

A.Companies are considered to be competitive if:

1. They provide same or similar products or services; and

2. They do business in the same or largely the same geographic areas; and

3. They target the same or largely the same demographics;

B. Marketing Advisory Services (MAS) are those services that are strategic in nature and have a material impact on a company’s ability to compete. Such services could include Branding, Positioning, Pricing, or Marketing Strategy.

C. Tactical Marketing Services are those services such as lead generation, graphic design, direct mail, telemarketing, or advertising placement, and website maintenance services.

D. A company is a MAS Client for the purpose of this policy if SOHO has provided revenue-generating Marketing Advisory Services to it within the previous three months or has a credible intent to do MAS business with SOHO within the next three months.

If a prospective client that competes with a current MAS client expresses the desire to do business with SOHO whereby SOHO would provide Marketing Advisory Services, SOHO shall first make an internal determination of whether it is in the best interest of all parties for SOHO to do business with both companies.

If SOHO determines that it is not in the best interest of all parties to do business with both companies, SOHO will not do business with both companies simultaneously.

If it is SOHO’s opinion that it is in the best interest of all parties for SOHO to do business with both companies, SOHO shall consult its current MAS Client for its opinion of SOHO having a business relationship with both companies. If that opinion is negative, then SOHO will not do business with both companies simultaneously. If that opinion is favorable, then SOHO shall have the option of pursuing a business relationship with the prospective MAS Client.

In the case of Tactical Marketing Services SOHO will provide the same service to competitors with the same demographic targets, concurrently, only if the design and management of those services can be adequately separated internally to prevent cross-communication of tactics and proprietary information.

Commitment to the integrity of its clients since its foundation, SOHO Prospecting has kept its reputation as a respectful ethical provider of Marketing Services in Ventura County and all across California.

Dale DeHart, President