policies

Privacy Policy

TABLE OF CONTENTS
SECTION 1.0 – INTRODUCTION
SECTION 2.0 – BASIC PRINCIPLES
SECTION 3.0 – CWG’S IBO RESPONSIBILITIES
SECTION 4.0 – AGREEMENT & GENERAL UNDERSTANDINGS
SECTION 5.0 – BUSINESS ENTITIES
SECTION 6.0 – POLICY VIOLATIONS
SECTION 7.0 – DISCIPLINARY ACTIONS
SECTION 8.0 – DISPUTE RESOLUTION
SECTION 9.0 – PAYMENT OF COMMISSIONS & BONUSES
SECTION 10.0 – ORDERING PRODUCT
SECTION 11.0 – CWG OPPORTUNITY
SECTION 12.0 – PROPRIETARY INFORMATION & TRADE SECRETS
SECTION 13.0 – PRIVACY POLICY
SECTION 14.0 – ADVERTISING, PROMOTIONAL MATERIAL, USE OF COMPANY NAMES AND TRADEMARKS
SECTION 15.0 – CIRCLE OF WEALTH GROUP
SECTION 16.0 – GLOSSARY OF TERMS
STATEMENT OF POLICIES & PROCEDURES
  • 1.1 INTRODUCTION
  • 1.2 Mutual Commitment Statement
  • Circle of Wealth Group, Inc. (hereinafter referred to as “CWG”) recognizes that in order to develop a long-term and mutually rewarding relationship with its Compensation Plan participants (hereinafter referred to as “Independent Business Owner(s)” or “IBOs”) must acknowledge and respect the true nature of the relationship and support the “Customers”..
    • In the spirit of mutual respect and understanding, CWG is committed to:
        • Provide prompt, professional and courteous personal service and communications
          to all of its IBOs and Customers;
        • Provide the highest level of quality services, at fair and reasonable prices;
        • Exchange or refund the purchase price of any product, service or membership as
          provided in our return policies contained herein;
        • Deliver services promptly and accurately;
        • Pay earned commissions accurately and on a timely basis;
        • Expedite orders if an error or unreasonable delay occurs;
        • Roll out new services and programs with IBOs input and planning;
        • Implement changes in the Compensation Plan or Policies and Procedures that
          affect the IBOs with input from the IBOs (note: such changes will be effective
          thirty (30) days after the date it was published);
        • Support, protect and defend the integrity of the CWG Income Opportunity;
        • Offer IBOs an opportunity to grow with CWG with such growth guided by the
          principles of Servant Leadership.
    • In return, CWG expects that its IBOs will:
        • Conduct themselves in a professional, honest, and considerate manner;
        • Present CWG Corporate and services information in an accurate and professional
          manner;
        • Present the Compensation Plan, services and refund policies
          contained herein
          in a complete and accurate manner;
        • Not make exaggerated income or service claims;
        • Make reasonable effort(s) to support and train other IBOs and Customers in their
          sales and marketing organization;
        • Not engage in cross-line sponsoring, solicitation of competing services,
          unhealthy competition or unethical business practices;
        • Provide positive guidance and training to CWG IBOs and Customers in their sales
          and marketing organizations while exercising caution to avoid interference with
          other IBO sales and marketing organizations. As such, an IBO is discouraged from
          providing training to other IBOs or Customers in a different sales and marketing
          organization;
        • Support, protect, and defend the integrity of the CWG Income Opportunity;
  • 1.3 Code of Ethics
    • CWG desires to provide its independent IBOs with the best Services, Training and
      Compensation Plan in the industry. Accordingly, CWG values constructive criticism and
      encourages the submission of written comments addressed to the CWG Compliance Team.
    • IBO’s negative and disparaging comments about CWG, its Services, the Agreement
      or Compensation Plan, made to CWG, or to the field or at any CWG meeting and/or event,
      or disruptive behavior at any meeting and/or event, serve no purpose other than to
      dampen the enthusiasm of other IBOs and Customers. CWG IBOs must not belittle
      CWG, fellow CWG IBOs, CWG Services, the Compensation Plan, or any and all CWG
      directors, officers, or employees, suppliers or agents. Such conduct represents a
      material breach of these Policies and Procedures and may be subject to sanctions as
      deemed appropriate by CWG.
    • CWG endorses the following code of ethics:
        • An IBO must show fairness, tolerance, and respect to all people associated with
          CWG, regardless of race, gender, social class or religion, thereby
          fostering a “positive atmosphere” of teamwork, good morale and community spirit.
        • An IBO shall strive to resolve business issues, including situations with other
          IBOs, by emphasizing tact, sensitivity, good will taking care not to create
          additional problems.
        • CWG IBOs must be honest, responsible, professional and conduct themselves with
          integrity.
        • CWG IBOs shall not make disparaging statements about CWG, other IBOs, CWG
          employees, suppliers or agents, Services, sales and marketing campaigns, or the
          Compensation Plan, or make statements that unreasonably offend, mislead or
          coerce others.
    • CWG may take appropriate action against An IBO if it determines, in its sole discretion,
      that An IBO’s conduct is detrimental, disruptive, or injurious to CWG or to
      other IBOs.
  • 1.4 CWG Policies & Procedures and Compensation Plan Incorporated into
    the IBO Agreement
    • Throughout these Policies & Procedures, when the term “Agreement” is used, it
      collectively refers to the CWG on-line Application, electronic signature process, the
      most current version of the Policies and Procedures in effect and any addendums thereto,
      the Compensation Plan, also referred to as the ‘CWG Platinum Reward Plan’ (attached
      hereto as “ADDENDUM 2” and incorporated herein for all purposes), and any and all social
      media guidelines or any other guidelines which may be implemented from time to time and
      any amendments thereto.
    • It is the responsibility of the Sponsoring IBO to provide the most current version of
      these Policies and Procedures (available on the CWG website), the Income Disclosure
      Statement, the CWG Compensation Plan, and any and all social media guidelines or any
      other guidelines which may be implemented from time to time and any amendments thereto
      to their downline IBOs.
  • 1.5 Purpose of Policies & Procedures
    • CWG is a direct to consumer, subscription based, training and education company that
      markets its Services through a network of independent business owners. To clearly define
      the relationship that exists between IBOs and CWG, and to explicitly set a
      standard for acceptable business conduct, CWG has established these Policies and
      Procedures.
    • CWG IBOs and Customers are required to comply with; (i) all of the Terms and Conditions
      set forth in the Agreement which CWG may amend from time to time in its sole discretion
      in accordance with the terms hereof; and (ii) all Federal, State, and/or local laws
      governing his, her and/or its CWG business.
    • CWG IBOs must review the information in these Policies and Procedures carefully. Should
      an IBO have any questions regarding a policy, rule or guidelines, the IBO is encouraged
      to seek an answer from the company FAQ, found on the website, their personal Sponsor, or
      the CWG Customer Service Team by submitting an email to: [email protected].
  • 1.6 Changes, Amendments, and Modifications
    • Because Federal, state, local and international laws, as well as the business
      environment, periodically change, CWG reserves the right to amend the CWG Agreement
      and the prices in its ‘CWG Services Price List'(attached hereto as “ADDENDUM 1” and
      incorporated herein for all purposes) in its sole and absolute discretion. Notification
      of amendments shall appear in all official CWG materials, CWG website, social media
      outlets or the IBO’s back office.
    • Any such amendment, change, or modification shall be effective thirty (30) days
      following notice by one of the following methods:
        • Posting on the official CWG website;
        • Electronic mail (e-mail); or
        • Any CWG communication channels or social media outlets (ie. Facebook, Instagram,
          Twitter and/or CWG App).
  • 2.1 BASIC PRINCIPLES
  • 2.2 Becoming An IBO
    • To become an IBO, an applicant must comply with the following requirements:
        • Be of the age of majority (not a minor) in his or her province or territory of
          residence. We require a minimum age of 18 or older.
        • Reside or have a valid address in the United States or U.S. territory, Canada,
          Australia or country wherein CWG is licensed to operate.
        • Have a valid tax payer identification number (i.e. Social Security
          Number,
          Federal Tax ID Number (TIN), federal Business Number, or proper personal
          identification number of the respective country;
        • Enter a verified mobile phone number or email address, which is not in use or
          associated with any other CWG accounts, which will be verified.
  • 2.3 New IBO Registration
    • A potential new IBO may self-enroll on any IBO/Sponsor’s website. In such event, CWG
      will accept the web enrollment and CWG Application by accepting the “electronic
      signature” stating the new IBO has accepted all terms and conditions of such the CWG
      Agreement. Please note that such electronic signature constitutes a legally binding
      agreement between the IBO and CWG.
    • Signed documents, including, but not limited to, IBO personal agreements, are legally
      binding contracts which must not be altered, tampered with or changed in any manner
      after they have been signed. False or misleading information, forged signatures or
      alterations to any document, including business registration forms, made after a
      document has been signed may lead to sanctions, up to and including involuntary
      termination of the IBO’s position.
    • If one applicant enrolls creating an Account listing a certain sponsor and enrolls a
      second time listing multiple sponsors, only the first completed form to be received by
      CWGwill be accepted. CWG reserves the right, at its sole discretion, to make the final
      decision with respect to all such disputes.
  • 3.1 CWG’S IBO RESPONSIBILITIES
  • 3.2 Correct Address
    • It is the responsibility of the IBO or Customer to make sure CWG has the correct contact
      information for all correspondence.
    • An IBO and/or Customer will need to allow up to seventy-two (72) hours for processing
      after the notice of address change has been received by CWG Support Team.
  • 3.3 Training and Leadership
    • Any CWG IBO who Sponsors another IBO into CWG must perform an authentic assistance and
      training function to ensure his or her sales and marketing organization is properly
      operating his or her CWG business. Sponsoring IBOs should have ongoing contact and
      communication with the IBOs in their sales and marketing organizations. (Examples of
      communication may include, but are not limited to, newsletters, written correspondence,
      telephone, direct contact, team conference calls, voice-mail, e-mail, personal meetings,
      accompaniment of downline IBOs to CWG meetings, training sessions, events, workshops,
      and any other related functions.)
    • A Sponsoring CWG IBO should monitor the IBOs in his or her sales and marketing
      organizations to ensure that IBOs do not make improper product or business claims or
      engage in any illegal or inappropriate conduct. Upon request, such IBO should be able to
      provide documented evidence to CWG of his or her ongoing fulfillment of the
      responsibilities of a Sponsor.
    • Sponsoring IBOs are encouraged to educate and train new IBOs about CWG’s Services,
      effective sales techniques, the CWG Compensation Plan, along with compliance with CWG
      Policies and Procedures and any and all social media guidelines or any other guidelines
      and amendments thereto implemented at that time. Marketing product is a required
      activity in CWG and must be emphasized in all recruiting presentations.
    • We emphasize and encourage all IBOs to sell CWG’s Services and services to Customers.
    • Use of Sales and marketing collateral. To promote both the Services and the opportunity
      CWG offers, IBOs must use the sales and marketing collateral and support materials
      produced by CWG. If CWG IBOs develop their own sales and marketing collateral and
      promotional

      materials, which includes Internet advertising, notwithstanding
      IBOs’ good intentions, along with the intentional violation of any number of statutes or
      regulatory laws affecting the CWG business. These violations, although they may be
      relatively few in number, could jeopardize the CWG opportunity for all IBOs.
      Accordingly, IBOs must submit via email all written sales and marketing collateral,
      promotional materials, advertisements, websites, training material, flyers, along with
      any other literature to the Compliance Team for approval prior to use. COMPLIANCE EMAIL:
      [email protected]. Unless the
      IBO receives specific written approval to use the material, the request shall be deemed
      denied. All IBOs shall safeguard and promote the good reputation of CWG and its
      Services. The marketing and promotion of CWG, the CWG opportunity, the Compensation
      Plan, and CWG Services shall be consistent with the public interest, and must avoid all
      discourteous, deceptive, misleading, unethical or immoral conduct or practices.

  • 3.4 Sponsorship
    • The Sponsor is the person who introduces an IBO or Customer to CWG, helps them complete
      their enrollment, and supports and trains those in their sales and marketing
      organization.
    • CWG recognizes the Sponsor as the name(s) shown on the first:
        • Physically signed CWG IBO Agreement on file; or
        • Electronically signed IBO Agreement from a website or an IBO website.
    • An IBO Agreement that contains notations such as “by phone” or the signatures of other
      individuals (i.e. Sponsors, Spouses, relatives, or friends) is not valid and will not be
      accepted by CWG.
    • CWG recognizes that each new prospect has the right to ultimately choose his or her own
      Sponsor, but CWG will not allow IBOs to engage in unethical sponsoring activities.
    • All active IBOs in good standing have the right to Sponsor and enroll others into CWG.
      While engaged in sponsoring activities, it is not uncommon to encounter situations when
      more than one IBO will approach the same prospect. It is the accepted courtesy that the
      new prospect will be sponsored by the first IBO who presented a comprehensive
      introduction to CWG Services or income opportunity.
  • 3.5 Unethical Sponsoring
    • Unethical sponsoring activities include, but are not limited to, enticing, bidding or
      engaging in unhealthy competition by attempting to acquire a prospect or new IBO away
      from a fellow IBO or influencing another IBO to transfer to a different sponsor.
    • Allegations of unethical sponsoring must be reported in writing to the CWG Compliance
      Team within the first 30 days of the new IBO enrollment in question. If the reports are
      substantiated, CWG may transfer the IBO or the IBO’s downline to another sponsor or
      organization without approval from the current up-line Sponsor or Placement IBOs. CWG
      remains the final authority in such cases.
    • CWG prohibits the act of “Stacking.” Stacking is the unauthorized manipulation of the
      CWG marketing system and/or the compensation plan in order to trigger commissions or
      cause a promotion off a direct or indirect IBO in their sales and marketing organization
      in an unearned manner. One example of stacking occurs when a Sponsor places IBO(s) under
      an inactive IBO lower in the compensation tree without his or her knowledge in order to
      trigger unearned qualification for commissioning purposes. Stacking is unethical and
      unacceptable behavior, and as such, it is a punishable offense with measures up to and
      including the termination of the independent IBO positions of all individuals and/or
      entities found to be directly involved.
    • Should IBOs engage in solicitation and/or enticement of members of another direct sales
      company to sell or distribute CWG Services to, they bear the risk of being sued by the
      other direct sales company. If any lawsuit, arbitration, or mediation is brought against
      an IBO alleging that they engaged in inappropriate sponsoring/recruiting activity of
      another company’s sales force or Customers, CWG will not pay any of IBO’s defense costs
      or legal fees, nor will CWG indemnify the IBO for any judgment, award, or settlement.
  • 3.6 Cross Sponsoring/ Recruiting Prohibition
    • “Cross sponsoring” is defined as the enrollment into a different line of sponsorship of
      an individual, or Business Entity, that already has a signed IBO Agreement. Actual or
      attempted cross sponsoring is not allowed. If cross sponsoring is verified by CWG,
      sanctions up to and including termination of an IBO’s position may be imposed. If an IBO
      Cross Sponsors, they must return to their original position or wait 6 months before
      rejoining CWG.
    • Cross Recruiting CWG members into your organization is a punishable offense including
      suspension, fines and possible termination.
    • The use of a Spouse’s or relative’s name, trade names, assumed names, DBA names,
      corporation, partnership, trust, Federal Business Numbers, or fictitious ID numbers to
      evade or circumvent this Policy is not permitted.
    • This Policy does not prohibit the transfer of an CWG business in accordance with CWG
      Transfer of Sale or Transfer Policy set forth in these Policies.
  • 3.7 Solicitation for Other Companies or Services
    • An IBO and/or Customer may participate in other direct sales, multilevel, network
      marketing or relationship marketing business ventures or marketing opportunities, as
      long as it is a non-competing product. However, during the Term of this Agreement and
      for six (6) months thereafter, an IBO may not sponsor/recruit any fellow CWG IBO or
      Customer for any other direct sales or network marketing business, unless that fellow
      IBO or Customer was personally sponsored by such IBO.
    • The terms “sponsor/recruit” means actual or attempted solicitation, enrollment,
      encouragement, or effort to influence in any other way (either directly or through a
      third party), another IBO or Customer to enroll or participate in any direct sales or
      network marketing opportunity. This conduct represents recruiting even if the IBO’s
      actions are in response to an inquiry made by another IBO or Customer.
    • During the term of this Agreement any CWG IBO must not sell, or entice others to sell,
      any competing Services, including training materials, to CWG Customers or IBOs. Any
      product or service in the same category as an CWG product or service is deemed to be
      competing (i.e., any competing product or service regardless of differences in cost or
      quality.)
    • However, an IBO may sell non-competing Services or services to the CWG Customers and
      IBOs that they personally sponsored.
    • An IBO may not display or bundle CWG Services or services, in sales literature, on a
      website or in sales meetings, with any other Services or services to avoid confusing or
      misleading a prospective Customer or IBO into believing there is a relationship between
      the CWG and non-CWG Services.
    • An IBO may not offer any non-CWG opportunity, Services at any CWG related meeting,
      event, seminar or convention, or immediately following a CWG event.
    • A violation of any of the provisions in this section shall constitute unreasonable and
      unwarranted contractual interference between CWG and its IBOs and would inflict
      irreparable harm on CWG. In such event, CWG may, at its sole discretion, impose any
      sanction it deems necessary and appropriate against such IBO or such IBO’s positions
      including termination, or seek immediate injunctive relief without the necessity of
      posting a bond.
  • 4.1 AGREEMENTS & GENERAL UNDERSTANDINGS
  • 4.2 Rights Granted
    • CWG hereby grants to the IBO a non-exclusive right, based upon the terms and conditions
      contained in the Agreement to:
        • Purchase CWG Services;
        • Promote and sell CWG Services; and
        • Sponsor new IBOs and Customers in countries where CWG is currently authorized to
          do business or becomes authorized to business in the future.
        • No feature of the Compensation Plan constitutes a personal purchase requirement
          to become an IBO, move up in rank in or otherwise fully participate in the
          Compensation Plan. No purchase is required of anyone at any time to fully
          participate as an IBO, outside of the monthly administrative fee for the IBO
          website, and reporting.
  • 4.3 Renewals and Expiration of the IBO Agreement
    • If the IBO allows his or her IBO Agreement to expire due to nonpayment, the IBO will
      lose any and all rights to his, her or its downline organization unless the IBO
      re-activates within sixty (60) days following the expiration of the Application.
        • If the former IBO re-activates within the sixty (60) day time limit, the IBO
          will resume the rank and position held immediately prior to the expiration of
          the IBO Agreement. However, such IBO’s paid as level will not be restored unless
          he, she and/or an entity qualifies at that payout level in the new month. The
          IBO is not eligible to receive commissions for the time period that the IBO’s
          position was expired.
        • Any IBO who was terminated or whose Agreement has expired and lapsed the sixty
          (60) day grace period is not eligible to re-apply for an CWG business for six
          (6) months following the expiration of the IBO Agreement.
        • The sales and marketing organization of the expired IBO will compress up to the
          immediate, active IBO in the hierarchy.
  • 4.4 Effect of Cancellation
    • Following an IBO’s cancellation for inactivity or voluntary or involuntary termination
      (collectively, a “cancellation”) such IBO:
        • Shall have no right, title, claim or interest to any commission or bonus from
          the sales generated by the IBO’s former sales and marketing organization or any
          other payments in association with the IBO’s former independent position;
        • Effectively waives any and all claims to property rights or any interest in or
          to the IBO’s former sales and marketing organization;
        • Shall receive commissions and bonuses only for the last full pay period in which
          he or she was active prior to cancellation, less any amounts withheld during an
          investigation preceding an involuntary cancellation, and less any other amounts
          owed to CWG.
  • 4.5 Modification of the IBO Agreement
    • An IBO may modify his or her existing IBO Agreement (i.e., add a Spouse or partner to
      the account, or change the form of ownership from an individual to a Business Entity
      owned by the IBO) by submitting a written request, accompanied by a new IBO Agreement
      and the Business Registration Form, if applicable, completed with fresh signatures (not
      a “crossed out” or “white-out” version of the first Agreement), and any appropriate
      supporting documentation.
  • 4.6 Unauthorized Transfer & Re-Enrollment
    • In the event an IBO discovers that an IBO in their sales and marketing organization has
      re-enrolled under a different IBO, the IBO has ninety (90) days from the date the
      downline IBO enrolled under a new IBO to notify the CWG Compliance team and request the
      downline IBO be transferred back to his/her downline. Upon the expiration of the ninety
      (90) day notice period, the right to re-claim a new IBO to his or her downline will be
      waived.
  • 4.7 Change of Sponsors or Placement for IBOs
    • Placement changes/corrections may be requested within a period of 10 Day period from the
      time of enrollment. Such adjustments require written permission directed to the Support
      Team submitted from the personal back office of the sponsor as well as the IBO to be
      moved and in some cases additional upline IBO(s).
    • Sponsor changes are generally not permitted. However, sponsor corrections can be made if
      they are reported to the Support Team within 24 hours from the time of enrollment.
      Sponsor corrections must be requested from the distributor back office of the current
      (original) sponsor, stating the reason that the correction needs to be made.
    • At the discretion of CWG, IBOs who have not ordered Services for at least 6 months, and
      who have not tendered a letter of termination resignation, are eligible to re-enroll in
      CWG under the Sponsor/Placement of their choice.
    • Upon written notice to CWG that a former IBO wishes to re-enroll, CWG will “compress”
      (close) the original account. A new CWG ID number will then be issued to the former IBO.
    • Such IBO does not retain former rank, downline, or rights to commission from his or her
      former sales and marketing organizations.
    • CWG reserves the right to correct Sponsor or Placement errors at any time and in
      whatever manner it deems necessary.
  • 4.8 Change Organizations
    • If an IBO wishes to transfer sales and marketing organizations, he or she must submit a
      letter of termination resignation to the CWG Customer Service Team and remain inactive
      (place no orders or be on an auto ship) with or in CWG for 6 months from the receipt of
      the letter before being eligible to re-enroll under a different Sponsor/Placement.
    • CWG retains the right to approve or deny any request to re-enroll after an IBO’s
      termination.
    • If re-enrollment is approved, the former IBO will be issued a new CWG ID number and will
      be required to submit a new IBO Agreement. The IBO will not be entitled to keep any
      former rank, sales and marketing organization, or rights to commission from any prior
      organization.
  • 4.9 Voluntary Termination
    • An IBO may immediately terminate his or her position by submitting a written notice or
      email to the CWG Compliance Team at [email protected] The
      written notice must include the following;
        • The IBO’s intent to terminate the Agreement; Date of termination;
        • CWG Identification Number;
        • Reason for terminating; and
        • An IBO may not use termination as a way to immediately change Sponsor and
          Placement. Instead, the IBO who has voluntarily terminated is not eligible to
          reapply for a position or have any financial interest in any CWG business for 6
          months from the receipt of the written notice of termination. They may also not
          promote CWG or attend events during their termination.
        • Signature
  • 4.10 Involuntary Termination
    • CWG reserves the right to terminate An IBO’s position for, but not limited to, the
      following reasons;
        • Violation of any Terms or Conditions of the IBO Agreement;
        • Violation of any provision of these Policies and Procedures in effect at the
          time the violation occurred or was discovered;
        • Violation of any provision in the Compensation Plan;
        • Violation of any applicable law, ordinance, or regulation regarding the CWG
          business;
        • Engaging in unethical business practices or violating standards of fair dealing;
          or Returning over $500 worth of Services, and/or sales tools for a refund within
          a 12-month period.
    • CWG will notify the IBO in writing through the email on file or certified mail, return
      receipt requested or overnight documented mail, at his or her last known address of its
      intent to terminate the IBO’s position and the reasons for termination. The IBO will
      have 15 calendar days from the date of mailing of such notice to respond in writing to
      the allegations or claims constituting cause for termination as stated in the notice.
      CWG will then have 30 calendar days from the date of receipt of the IBO’s response to
      render a final decision as to termination.
    • If a decision is made by CWG to terminate the IBO’s position, CWG will inform the IBO in
      writing that the position is terminated effective as of the date of the written
      notification.
    • If the termination is not rescinded, the termination will be effective as of the date of
      the original termination notice by CWG. The former IBO shall thereafter be prohibited
      from using the names, marks or signs, labels, stationery, advertising, or business
      material referring to or relating to any CWG Service. CWG will notify the active Sponsor
      within 10 days after termination. The organization of the terminated IBO will “roll up”
      to the next immediate active direct Sponsor on record.
    • The CWG IBO who is involuntarily terminated by CWG may not reapply for a position,
      either under his or her present name or any other name or entity, without the express
      written consent of an officer of CWG, following a review by the CWG Compliance
      Committee. In any event, such IBO may not re- apply for a position for 12 months from
      the date of termination.
  • 5.1 BUSINESS ENTITIES
  • 5.2 Definition
    • A corporation, partnership, or trust (collectively referred to as a (“Business Entity”)
      may apply to be an IBO.
    • An IBO may change their status under the same Sponsor from an individual to a
      partnership, corporation, trust or from one type of business entity to another.
  • 5.3 Definition
    • IBOs are independent contractors acting in the capacity of a wholly independent
      marketing representative who establish and services retail customers for CWG
      Services. IBO status, as such does not constitute either a sale of a security, franchise
      or a distributorship (exclusive or otherwise), and absolutely no fees have been or will
      be required from IBO for the right to market and sell CWG Services pursuant to the IBO
      Agreement, outside of the monthly administrative fee charged for maintaining the IBO’s
      replicated website and reporting capabilities. The IBO Agreement is not intended and
      shall not be construed to create a relationship of employer-employee, agency,
      partnership, or joint venture between IBO and any other participant in the CWG marketing
      plan and/or Circle of Wealth Group. As an independent contractor, IBO will:
      (i) comply with all applicable federal, provincial and local laws, rules and regulations
      pertaining to the IBO Agreement, including the sale, distribution and advertising of CWG
      Services, and (ii) at IBO’s own expense, complete all filings, and obtain such licenses
      as are required by applicable federal, provincial and local laws, rules and regulations,
      with respect to the IBO Agreement and IBO’s activities as an IBO.
    • IBOs have no authority to bind CWG to any obligation. It is each IBO’s
      responsibility to pay all income, local or applicable taxes as an independent
      contractor, and IBOs are not eligible for employee benefits, such as unemployment
      compensation, worker’s compensation or minimum wages. CWG encourages its IBOs to set
      their own hours and to supply all of their own equipment and tools for operating their
      CWG business, such as telephones, transportation, professional services, office
      equipment and supplies. Further, IBOs should determine their own methods of sale, so
      long as they comply with the policies of Company. Without limiting the generality of the
      foregoing, IBOs shall be fully responsible for (i) all applicable federal, state and
      local withholding taxes, worker’s compensation contributions license requirements and
      fees related to the IBO’s earnings and activities as an IBO, and (ii) all expenses
      incurred in connection with the operation of the IBO’s Company-related business,
      including but not limited to travel, meals, accommodation, secretarial, office,
      telephone and other business expenses.
    • The CWG IBO is fully responsible for all of his or her verbal and written communications
      made regarding CWG Services, and the Compensation Plan that are not expressly contained
      within official CWG materials. IBOs shall indemnify and hold harmless CWG, its
      directors, officers, employees, product suppliers and agents from any and against all
      liability including judgments, civil penalties, refunds, lawyer fees and court costs
      incurred by CWG as a result of the IBO’s unauthorized representations or actions. This
      provision shall survive the termination of the CWG IBO Agreement.
  • 5.4 Insurance
    • Business Pursuits Coverage. CWG encourages IBOs to arrange insurance coverage for their
      business. A homeowner’s insurance policy does not cover business related injuries, or
      the theft of, or damage to, inventory or business equipment. CWG IBOs need to contact
      their insurance agent to make certain their business property is protected. In most
      instances, this may be accomplished with a “Business Pursuit” endorsement to an existing
      homeowner’s policy.
    • If an IBO has questions about, or believes any errors have been made regarding
      commissions, bonuses, business reports, genealogy, orders or charges, the IBO must
      notify CWG in writing within thirty (30) days of the date the error or incident in
      question occurred. Any such errors, omissions or problems not reported within thirty
      (30) days shall be deemed waived by the IBO.
  • 6.1 POLICY VIOLATIONS
  • 6.2 Reporting Policy Violation
    • An IBO who observes a policy violation by another IBO, IBO or Customer associated with
      CWG should submit an e-mail [email protected] any and
      all violations directly to the CWG Corporate office. The message shall set forth the
      details of the incident as follows: The nature of the violation:
        • Specific facts to support the allegations;
        • Dates;
        • Number of occurrences;
        • Persons involved; and
        • Supporting documentation
    • Once the matter has been presented to CWG, it will be researched thoroughly by the
      Compliance Team and appropriate action will be taken if required.
    • This section refers to the general reporting of Policy violations as observed by other
      IBOs for the mutual effort to support, protect, and defend the integrity of the CWG
      business and opportunity. If an IBO has a grievance or complaint against another IBO
      which directly relates to his or her CWG business, the Procedures set forth in these
      Policies must be followed.
  • 6.3 Adherence to the CWG Compensation Plan
    • An IBO must adhere to the terms of the CWG Compensation Plan as set forth in these
      Policies and Procedures as well as in official CWG literature. Deviation from the
      Compensation Plan is prohibited.
    • An IBO shall not offer the CWG opportunity through, or in combination with, any other
      system, program, or method of marketing other than that specifically set forth in
      official CWG literature.
    • An IBO shall not require or encourage a current or prospective IBO to participate in CWG
      in any manner that varies from the Compensation Plan as set forth in official CWG
      literature.
    • An IBO shall not require or encourage a current or prospective IBO to make a purchase
      from or payment to any individual or other entity as a condition to participating in the
      CWG Compensation Plan.
  • 6.4 Adherence to Laws and Ordinances
    • Many cities, counties and townships have laws regulating certain home- based businesses.
      IBOs must check their local laws and obey the laws that do apply to them.
    • An IBO or Customer shall comply with all Federal and local laws and regulations in their
      conduct of his or her CWG business.
    • An IBO accepts sole responsibility for and agrees to pay all fines and incur all
      liabilities for his or her actions that violate any laws or ordinances.
  • 6.5 Compliance with Applicable Income Tax Laws
    • An IBO accepts sole responsibility for and agrees to pay all Federal, Provincial and
      local taxes on any income generated as an independent IBO, and further agrees to
      indemnify CWG from any failure to pay such tax amounts when due.
    • If an IBO’s business is tax exempt, the Federal Business Number must be provided to CWG
      in writing.
    • CWG encourages all IBOs to consult with a tax advisor for additional information for
      their business. CWG is required to change and remit sales tax to the various states or
      provinces based on the retail price. (Receipt of trips, prizes or awards in the amount
      of $600.00 or more.)
  • 6.6 One CWG Business Per IBO
    • An IBO may operate or have an ownership interest, legal or equitable, as a sole
      proprietorship, partner, shareholder, trustee, or beneficiary, in only one (1) CWG
      business. No individual (together with their spouse) may have, operate or receive
      compensation from more than one CWG business. Individuals of the same family unit,
      excluding spouses, may each enter into or have an interest in their own separate CWG
      businesses, only if each subsequent family position is placed frontline to the first
      family member enrolled. A “family unit” is defined as parents or dependent children
      living at or doing business at the same address. Each position must build their position
      separate and independent of the other or the position will be deemed to be stacking.
  • 6.7 Actions of Household Members or Affiliated Parties
    • If any member of an IBO’s immediate household engages in any activity which, if
      performed by the IBO, would violate any provision of the Agreement, such activity will
      be deemed a violation by the IBO and CWG may take disciplinary action pursuant to these
      Policies and Procedures against the IBO. Similarly, if any individual associated in any
      way with a corporation, partnership, trust or other entity (collectively “Business
      Entity”) violates the Agreement, such action(s) will be deemed a violation by the
      Business Entity, and CWG may take disciplinary action against the Business Entity.
      Likewise, if an IBO enrolls in CWG as a Business Entity, each Affiliated Party of the
      Business Entity shall be personally and individually bound to, and must comply with, the
      Terms and Conditions of the Agreement.
  • 6.8 Identification Numbers and Pay-Out
    • Each IBO is required to provide his or her federal Social Security Number or Federal Tax
      Identification Number, if located in the United States or any of its territories to CWG
      at the time IBO initiates a transfer of monies or earnings accumulated in the IBO’s
      Wallet. The transferring and disbursement of commission payments or bonuses acquired is
      known as a Pay- Out and CWG reserves the right to withhold Pay-Out from any IBO who
      fails to provide such information or who provides false information.
    • Upon enrollment, CWG will provide a CWG Identification Number to the IBO. This number
      will be used to place orders, structure organizations, and track commissions and
      bonuses.
  • 6.9 Sell, Assign or Delegate Ownership
    • In order to preserve the integrity of the hierarchical structure, it is necessary for
      CWG to place restrictions on the transfer, assignment, or sale of a position.
    • An IBO may not sell or assign his or her rights or delegate his or her position as An
      IBO without prior written approval by CWG, which approval will not be unreasonably
      withheld. Any attempted sale, assignment, or delegation without such approval may be
      voided at the discretion of CWG.
    • Should the sale be approved by CWG, the Buyer assumes the position of the Seller at the
      current qualified title, but at the current “paid as” rank, at the time of the sale and
      acquires the Seller’s Downline.
    • To request corporate authorization for a sale or transfer of an CWG position, the
      following items must be submitted to the CWG Compliance Team:
        • A Sale/Transfer of Position Form properly completed, with the requisite
          signatures.
        • A copy of the Sales Agreement signed, dated and notarized by both Buyer and
          Seller.
        • An IBO Agreement completed and signed by the signed by the Buyer and proof of
          good standing;
        • Payment of the $250 administration fee paid by Seller;
        • Any additional supporting documentation requested by CWG.
    • Any debt obligations that either Seller or Buyer may have with CWG must be satisfied
      prior to the approval of the sale or transfer by CWG.
    • An IBO who sells his or her position is not eligible to re-enroll as a CWGIBO in any
      organization for six (6) full calendar months following the date of the sale except as
      otherwise expressly set forth in these Policies and Procedures.
  • 6.10 Separating an CWG Business
    • Pending a divorce or dissolution of a partnership or other business entity, the parties
      must adopt one of the following methods of operation:
        • One of the parties may, with the written consent of the other(s), operate the
          CWG business whereby the relinquishing Spouse (which term herein means either an
          individual that is legally married or an individual that is party to a legally
          recognized common law relationship), shareholders, partners, members or trustees
          authorize CWG to deal directly and solely with the other Spouse, non-
          relinquishing shareholder, partner, member or trustee;
        • The parties may continue to operate the CWG business jointly on a “business as
          usual” basis, whereupon all compensation paid by CWG will be paid in the name
          designated as the IBOs or in the name of the entity to be divided, as the
          parties may independently agree between them. If no name is stipulated, CWG will
          pay compensation to the name on record and in such event, the IBO named on the
          account shall indemnify CWG from any claims from the other business owner(s) or
          the other Spouse with respect to such payment.
    • CWG recognizes only one sales and marketing organization and will issue only one
      commission payment transfer per CWG business per commission cycle. Under no
      circumstances will the hierarchy of an organization be divided, nor will CWG split
      commission and/or bonuses.
    • If a relinquishing Spouse, partner or owner of the business has completely relinquished
      (“Relinquishing Party”), in writing, all rights to the original CWG business, he or she
      may immediately thereafter re-enroll under the Sponsor and Placement of his or her
      choice. In such cases, however, the Relinquishing Party shall have no rights to, and
      shall not solicit, any IBO or active Customer in the former organization, and must
      develop a new business in the same manner as any other new CWG IBO. An IBO in the
      Relinquishing Party’s former Downline who wishes to transfer to the Relinquishing
      Party’s new organization or to any other organization, must comply with the requirements
      in Section 4.0.
  • 6.11 Succession
    • The Agreement shall be binding upon and inure to the benefit of the parties and their
      respective successors and assigns.
    • Upon the death or incapacity of an IBO, the IBO’s business may be passed on to his or
      her legal successors in interest (successor). Whenever an CWG business is transferred by
      will or other testamentary process, the successor acquires the right to collect all
      bonuses and commissions of the deceased IBO’s sales organization. The successor must:
        • Complete and sign a new CWG IBO Agreement;
        • Comply with the Terms and provisions of the IBO Agreement; and
        • Meet all of the qualifications for the last rank achieved by the former IBO.
    • Bonus and commission of an CWG business transferred based on this section will be paid
      in a single transfer to the successor. The successor must provide CWG with an “address
      of record” to which all bonus and commission Payments will be sent. Payments will be
      based on the current performance of the position, not the highest rank or volume
      achieved.
    • If the business is bequeathed to joint devisees (successors), they must form a business
      entity and acquire a federal Business Number. CWG will issue all bonus and commission
      payments to the managing business entity only.
    • Appropriate legal documentation must be submitted to CWG Compliance Team to ensure the
      transfer is done properly. To affect a testamentary transfer of an CWG business, the
      successor must provide the following to CWG Compliance Team;
        • A certified copy of the death certificate; and
        • A notarized copy of the will or other appropriate legal documentation
          establishing the successor’s right to the CWG business.
    • To complete a transfer of the CWG business because of incapacity, the successor must
      provide the following to the CWG Compliance Team;
        • A notarized copy of an appointment as trustee;
        • A notarized copy of the trust document or other appropriate legal documentation
          establishing the trustee’s right to administer the CWG business; and
        • A completed IBO Agreement executed by the trustee.
    • If the successor is already an existing IBO, CWG will allow such IBO to keep his or her
      own position plus the inherited position active for up to six
      (6) months. By the end
      of the six (6) month period, the IBO must have compressed (if applicable), sold or
      otherwise transferred either the existing position or the inherited position.
    • If the successor wishes to terminate the CWG position, he or she must submit a notarized
      statement stating the desire to terminate the position, along with a certified copy of
      the death certificate, appointment as trustee, and/or any other appropriate legal
      documentation.
        • Upon written request, CWG may grant a 1month bereavement waiver and pay out at
          the last “paid as” rank.
  • 7.1 DISCIPLINARY ACTIONS
  • 7.2 Imposition of Disciplinary Action – Purpose
    • It is the spirit of CWG that integrity and fairness should pervade among its IBOs,
      thereby providing everyone with an equal opportunity to build a successful business.
      Therefore, CWG reserves the right to impose disciplinary sanctions at any time, when it
      has determined that an IBO has violated the Agreement or any of these Policies and
      Procedures or the Compensation Plan as they may be amended from time to time by CWG in
      accordance herewith.
  • 7.3 Consequences and Remedies of Breach
    • Disciplinary actions may include one or more of the following:
        • Monitoring an IBO’s conduct over a specified period of time to assure
          compliance;
        • Issuance of a written warning or requiring the IBO to take immediate corrective
          action;
        • Imposition of a fine (which may be imposed immediately or withheld from future
          commission payments) or the withholding of commission payments (“Commission
          Hold”) until the matter causing the Commission Hold is resolved or until CWG
          receives adequate additional assurances from the IBO to ensure future
          compliance;
        • Suspension from participation in Company or IBO events, rewards, or recognition;

          Suspension of the CWG IBO Agreement and
          position for one or more pay periods;

        • Involuntary termination of the IBO’s Agreement and position;
        • Any other measure which CWG deems feasible and appropriate to justly resolve
          injuries caused by the IBO’s Policy violation or contractual breach; OR
        • Legal proceedings for monetary or equitable relief.
  • 7.4 Suspension Procedures
    • First Violation: Counseling and initial warning letter.
        • A first violation usually occurs because the IBO is not familiar with the
          Policies and Procedures or the law. Counseling and the initial warning provide
          an opportunity for Compliance to bring to the attention of the CWG the Policies
          and Procedures and the specific violation, and to provide
          counseling on
          complying with the Policies and Procedures and applicable laws. Compliance will
          also describe expectations and steps the IBO must take to resolve the violation
          including, but not limited to, either removing or revising the non-compliant
          claim or how to remedy other policy violations. Within 3 days of this notice,
          Compliance will determine if the non-compliant material or other policy
          violation has been remediated. If so, Compliance will close the file. If not,
          Compliance will proceed to 2nd Violation notice.
    • Second Violation: Second warning letter and temporary suspension
        • Although it is hoped that the IBO will promptly correct the violation(s), CWG
          recognizes that this may not always occur. The second written warning indicates
          the seriousness of repeated violations and will prompt a temporary suspension of
          the IBO’s account. During the suspension period, the IBO waives any and all
          rights to Pay-Out and must submit a signed a reinstatement letter wherein the
          IBO acknowledges the violation(s) and describes the steps taken to correct the
          violation(s). Once the reinstatement letter is accepted by CWG, the suspension
          will be lifted. The IBO may be subject to additional discipline up to and
          including termination if the violation is not remedied or further violations
          occur.
    • Third Violation: Termination
        • As described above, CWG will try to exercise the progressive nature of the
          Discipline Policy by first providing warnings, a final written warning and
          suspension and commissions forfeiture before proceeding to termination; however,
          CWG reserves the right to combine and omit steps depending on the circumstances
          of each situation and the nature of the violation. Furthermore, IBO may be
          terminated without prior notice or disciplinary action, as authorized by the
          Policies and Procedures.
  • 8.1 DISPUTE RESOLUTION
  • 8.2 Grievances
    • If an IBO has a grievance or complaint against another IBO regarding any practice or
      conduct relating to their respective CWG businesses, he or she is encouraged to resolve
      the issue directly with the other party. If an agreement cannot be reached, it must be
      reported directly to the CWG Compliance Team as outlined below in this Section.
    • The CWG Compliance Team will be the final authority on settling such grievance or
      complaint and its written decision shall be final and binding on the IBOs involved.
    • CWG will confine its involvement to disputes regarding CWG business matters only. CWG
      will not decide issues that involve personality conflicts or unprofessional conduct by
      or between IBOs outside the context of an CWG business. These issues go beyond the scope
      of CWG and may not be used to justify a Sponsor or Placement change or a transfer to
      another CWG organization.
    • CWG does not consider, enforce, or mediate third party agreements between IBOs, nor does
      it provide names, funding, or advice for obtaining outside legal counsel.
    • Process for Grievances:
        • The CWG IBO should submit a letter of complaint (e-mail will be accepted)
          directly to the CWG Compliance Team. The letter shall set forth the details of
          the incident as follows;
            • The nature of the violation;
            • Specific facts to support the allegations;
            • Dates;
            • Number of occurrences;
            • Persons involved; and
            • Supporting documentation.
        • Upon receipt of the written complaint, CWG will conduct an investigation
          according to the following procedures;
            • The Compliance Team will send an acknowledgment of receipt to the
              complaining IBO;
            • The Compliance Team will provide a verbal or written notice of the
              allegation to the IBO under investigation. If a written notice is sent
              to the IBO, he or she will have 10 business days from the date of the
              notification letter to present all information relating to the incident
              for review by CWG.
            • The Compliance Team will thoroughly investigate the complaint, consider
              all the submitted information it deems relevant, including information
              from collateral sources. Due to the unique nature of each situation,
              determinations of the appropriate remedy will be on a case by case
              basis, and the length of time to reach a resolution will vary.
            • During the course of the investigation, the Compliance Team will only
              provide periodic updates simply stating that the investigation is
              ongoing. No other information will be released during this time. IBO
              calls, letters, and requests for “progress reports” during the course of
              the investigation will not be answered or returned.
        • CWG will make a final decisi Von and timely notify the CWGIBOs involved.
  • 8.3 Mediation
    • IBO and CWG (collectively “the Parties”) recognize disputes and differences may arise
      between the Parties and therefore agree it is in their best interest to appoint an
      impartial mediator to resolve such disputes as they arise. Additionally, the Parties
      recognize that litigation in court can be time consuming and expensive, hence THE
      PARTIES AGREE TO THE FOLLOWING:
    • The Parties hereto agree to refer the following matters and responsibilities to the
      Mediator:
        • The Mediator shall conduct the mediation based on the principle of party
          self-determination, in which the Parties come to a voluntary, uncoerced decision
          where each party makes free and informed choices.
        • The Mediator shall conduct any necessary separate or ex parte meetings and other
          communications with parties or representatives, before, during, and after any
          scheduled mediation conference.
        • The Parties should exchange all documents pertinent to the relief requested. The
          Mediator may request the exchange of memoranda and other information; items that
          a party wishes to keep confidential may be sent to the Mediator in a separate
          communication.
        • The Mediator does not have the authority to issue a settlement, but will help
          facilitate a satisfactory resolution of the dispute.
        • The Mediator will not make decisions for a Party or act as an arbitrator. i.
          Should a complete settlement of some or all issues not be achieved, the Mediator
          may continue to communicate with the Parties following the mediation conference.
        • The Mediator is not a legal representative of any party.
        • The Mediator shall set the date, time, and place for each session of the
          mediation conference and the Parties shall respond in a timely manner.
    • The Mediator shall direct the Parties to file statements of their respective claims,
      legal submissions and reliefs claimed. Each party will file statements of defense in
      reply to the statements of claims of others. The Mediator shall allow the Parties to
      produce documents in support of their claims.
    • The Mediator shall allow the Parties to be represented by their respective advocates,
      who have the authority to consummate a settlement. Any party may participate without
      representation (pro se).
    • Mediation sessions and related mediation communications are private proceedings. The
      Parties and their representatives may attend mediation sessions. Other persons may
      attend only with the permission of the Parties and with the consent of the Mediator.
  • 8.4 Termination of Mediation
    • The mediation shall be terminated:
        • By the execution of a settlement agreement by the Parties; or
        • By a written or verbal declaration of the Mediator to the effect that further
          efforts at mediation would not contribute to a resolution of the Parties’
          dispute; or
        • By a written or verbal declaration of all Parties to the effect that the
          mediation proceedings are terminated; or
        • When there has been no communication between the Mediator and any party or
          party’s representative for twenty (21) days following the conclusion of the
          mediation conference.
    • Each Party will pay its own costs and expense of the mediation unless the Parties agree
      otherwise. The expenses of participants for either side shall be paid by the party
      requesting the attendance of such participants.
    • The Parties agree that all mediation communications are privileged and not subject to
      discovery or admissible in evidence in a proceeding unless waived or precluded by both
      Parties or unless the evidence would otherwise be admissible or subject to discovery if
      it were not by reason of its disclosure or use in mediation.
    • Jurisdiction and venue of any controversy or claim brought under this mediation
      provision shall be submitted to a Mediator with a principal office in New York City, New
      York. The mediation shall occur at the office of the Mediator or at any neutral location
      located in New York City, New York. The Parties further agree that the laws of the State
      of New York shall govern all matters, claims or controversy submitted to mediation
      pursuant to the Agreement.
  • 8.5 Severability
    • If any provision of these Policies and Procedures is found to be invalid, or
      unenforceable for any reason, only the invalid provision shall be severed. The remaining
      terms and provisions hereof shall remain in full force and shall be construed as if such
      invalid or unenforceable provision never had comprised a part of these Policies and
      Procedures.
  • 8.6 Waiver
    • Only an officer of CWG can, in writing, affect a waiver of the CWG Policies and
      Procedures. CWG’s waiver of any particular breach by An IBO shall not affect CWG’s
      rights with respect to any subsequent breach, nor shall it affect the rights or
      obligations of any other IBO.
    • The existence of any claim or cause of action of an IBO against CWG shall not constitute
      a defense to CWG’s enforcement of any term or provision of these Policies and
      Procedures.
  • 8.7 Governing Law
    • Subject to and without waiving the terms set forth in Sections 8.2 (Mediation) and 8.3
      (Termination of Mediation) above, jurisdiction and venue of any controversy or claim
      arising from the Agreement or between CWG and IBO, shall be in New York City, New York.
      The law of the State of New York shall govern all matters relating to or arising from
      the Agreement or between CWG and IBO.
  • 9.1 PAYMENT OF COMMISIONS & BONUSES
  • 9.2 Bonus and Commission Qualifications
    • An IBO must be active and in compliance with any and all CWG Policies and Procedures set
      forth herein, along with all guidelines implemented to qualify for bonuses and
      commissions. So long as an IBO complies with the terms and conditions set forth in the
      Agreement, CWG shall pay commissions to such IBOs in accordance with the Compensation
      Plan and any amendments thereto.
    • CWG will not issue a payment earned of any form to an IBO without the receipt of the
      administrative fee and completed electronic CWG Application.
    • CWG reserves the right to postpone bonus and commission payments until such time the
      cumulative amount exceeds $50.00.
  • 9.3 Computation of Commissions and Discrepancies
    • In order to qualify to receive commissions and/or bonuses, an IBO must be in good
      standing and comply with the Terms of the Application and these Policies and Procedures.
      Commissions, bonuses, overrides, and achievement levels are calculated each month.
    • An IBO must review his or her monthly statement and bonus/commission reports promptly
      and report any discrepancies within thirty (30) days of receipt. After the thirty (30)
      day “grace period” no additional requests will be considered for commission
      recalculations.
    • For additional information on payment of commissions, please review the Compensation
      Plan.
  • 9.4 Adjustments to Bonuses and Commissions for Returned Services or
    IBO Memberships.
    • An IBO receives bonuses and commissions based on the actual sales of Services to end
      consumers and to IBOs through service purchases. When a service is returned to CWG for a
      refund from the end consumer or by An IBO, the bonuses and commissions attributable to
      the returned service will be deducted from the IBO who received bonuses or commissions
      on such sales. Deductions will occur in the month in which the refund is given and
      continue every pay period thereafter until the bonus/and or commission is recovered.
    • In the event that an IBO terminates his or her position, and the amounts of the bonuses
      or commissions attributable to the returned Services have not yet been fully recovered
      by CWG, the remainder of the outstanding balance may be offset against any other amounts
      that may be owed by CWG to the terminated IBO.
    • For additional information on payment of commissions, please review the Compensation
      Plan.
  • 10.1 ORDERING SERVICES
  • 10.2 General Service Ordering Policies
    • Bonus Buying” is strictly and absolutely prohibited. Bonus Buying includes; (a)
      the enrollment of individuals or entities without the knowledge of and/or execution of
      an Application by such individuals or Business Entities; (b) the fraudulent enrollment
      of an individual or entity as an IBO or Customer; (c) the enrollment or attempted
      enrollment of non-existent individuals or Business Entities as IBOs or Customers
      (“phantoms”); (d) purchasing CWG Services or services on behalf of another IBO or
      Customer, or under another IBO’s or Customer’s ID number, to qualify for commissions or
      bonuses; and/or (e) any other mechanism or artifice to qualify for rank advancement,
      incentives, prizes, commissions, or bonuses that is not driven by bona fide product or
      service purchases by end consumers.
    • CWG requires that IBOs use their own credit cards and not allow others to use them. An
      IBO shall not use another IBO’s or Customer’s credit card or debit account to enroll in
      CWG or purchase Services without the account holder’s written permission. Such
      documentation must be kept by the IBO indefinitely in case CWG needs to reference this.
    • Regarding an order with an invalid or incorrect payment, CWG will attempt to contact the
      IBO by phone, mail or e-mail in order to obtain another form of payment. If these
      attempts are unsuccessful after the expiration of seven (7) business days, the order
      will be canceled.
    • Prices are subject to change without notice.
    • An IBO or Customer who is a recipient of an incorrect order must notify CWG within three
      (3) calendar days from receipt of the order and follow the Procedures as set forth in
      these Policies and Procedures, along with the Return/Exchange Policies and any and all
      guidelines instated and effective and any amendments thereto.
  • 10.3 Sales to Customers
    • Sales to retail customers must be done directly through IBOs’ replicated websites.
    • IBOs will comply with applicable consumer protection laws and regulations (including any
      consumer rights to receive specific notices and any rights to return services) afforded
      consumers under applicable consumer protection legislation.
    • The customer should contact CWG within seven (7) days of the initial sale.
  • 10.4 Insufficient Funds
    • All electronic payments that are declined for insufficient funds will be automatically
      re-submitted for payment.
    • Any outstanding balance owed to CWG by an IBO or Customer of An IBO from NSF (non-
      sufficient funds) or insufficient fund fees (ACH), will be withheld by CWG from that
      IBO’s future bonus and commission funds.
    • All transactions involving insufficient funds through ACH or credit card, which are not
      resolved in a timely manner by the IBO, constitute grounds for disciplinary sanctions or
      termination of the account.
    • If a credit card order or automatic debit is declined the first time, the Customer or
      IBO will be contacted directly and a request for an alternate form of payment will be
      made before any product will be shipped. If payment is declined a second time, the
      Customer or IBO may be deemed ineligible to purchase CWG Services or services or
      participate in the monthly auto ship. Note: Participation by IBOs in CWG’s monthly auto
      ship, which is a recurring service order program, is entirely optional, and is not
      required in order to become An IBO, move up in rank or otherwise, fully participate in
      the Rewards Program.
  • 10.5 Credit Card Purchases
    • Credit card purchases may only be made by the individual whose name and address are on
      the credit card. Any IBO or Customer who uses another individual’s credit card to pay
      for purchases risks having his/her Account being placed on suspension pending an
      investigation and resolution of any complaints regarding unauthorized charges. CWG
      considers such transactions fraudulent and will report them to the proper authorities
      for settlement.
    • Under no circumstance will any IBO and/or Customer charge back any credit card
      purchases. Any IBO and/or Customer who does so will immediately lose all credit card
      ordering privileges until the charges are replaced with certified funds. If an erroneous
      charge is applied to an IBO and/or Customer’s credit card, the IBO or Customer should
      immediately contact the CWG Support Team via email at [email protected] to initiate an
      investigation and resolution.
    • If an IBO or Customer notifies his/or her banking institution and requests a chargeback
      for the amount of the purchase, the person’s Account will be automatically closed
      indefinitely upon CWG’s notification of the disputed purchase.
  • 10.6 Sales Tax Obligation
    • The IBO shall comply with all federal and local taxes and regulations governing the sale
      of CWG Services.
    • CWG may collect and remit sales tax, on IBO orders. When orders are placed with CWG,
      sales tax is prepaid based upon the suggested retail price. CWG will remit the sales tax
      to the appropriate Provincial and local jurisdictions. The IBO may recover the sales tax
      when he or she makes a sale. CWGIBOs are responsible for any additional sales taxes due
      on Services marked up and sold at a higher price.
    • CWG encourages each IBO to consult with a tax advisor for additional information for his
      or her business.
    • CWG may be required to charge and remit sales tax to the various states and U.S
      territories based on the retail price.
  • 10.7 Refund Policy
    • CWG Customers:
        • If within the first seven (7) days, you are not satisfied with the service you must contact support by logging into im.academy and clicking the support button for a full refund of the service amount.
    • CWG does not refund any purchases completed. There are no exceptions. All purchases are charged and refunded in U.S. Dollars. All refunds and exchanges will also be refunded or exchanged in U.S. Dollars. Circle of Wealth Group. is not responsible for fluctuating exchange rate.
  • 11.1 CWG OPPORTUNITY
  • 11.2 Presentation of Compensation Plan – Income Claims
    • In presenting the CWG opportunity to potential Customers and IBOs, an IBO is required to
      comply with the following provisions:
    • AN IBO shall not misquote or omit any significant material fact about the Compensation
      Plan.
        • An IBO shall make it clear that the Compensation Plan is based upon sales of CWG
          Services and upon the sponsoring of other IBOs.
        • An IBO shall make it clear that success can be achieved only through substantial
          and diligent independent efforts.
        • An IBO shall not make income projections, claims, or guarantees while presenting
          or discussing the CWG opportunity or Compensation Plan to prospective IBOs or
          Customers. An IBO should inform all IBOs that success requires substantial work.
          Income claims include, but not limited to, copies of Paylution checks, banks
          statements, rank earnings, tax documents, trading profits, Lifestyle claims and
          photos. I.e. Cash, Exotic cars, yachts. Income claims are prohibited at events
          and/or posting on Social Media, Websites, or Videos. If found to have posted
          income or lifestyle claims on social media, you will receive a warning to remove
          the post immediately. Repeated offenses will result in suspension or possible
          termination.
        • An IBO may not make any claims or show trading results based on or regarding
          Services offered by CWG, except those contained in official CWG literature.
        • An IBO may not use official CWG material to promote the CWG business opportunity
          in any country where CWG has not established a “presence” or is duly authorized
          to conduct business.
  • 11.3 Events
    • IBOs are limited to charging $30.00 per person for events.
    • Compliance must approve all marketing materials.
  • 11.4 Trading Policies
    • IBOs or customers are strictly prohibited from selling Signals, Trading Bots,
      Auto-traders or taking investments to trade. Any violation of these will result in
      immediate termination.
    • An IBO must always cover profits when posting winning trades on social media. Trading
      Challenges or projected Growth charts are prohibited.
  • 11.5 Sales Requirements Are Governed by the Compensation Plan
    • There are no exclusive territories granted to anyone. No franchise fees are applicable
      to an CWG business. CWG Services may only be sold where CWG is licensed or otherwise
      authorized to conduct business.
  • 12.1 PROPRIETARY INFORMATION & TRADE SECRETS
  • 12.2 Business Reports, Lists, and Proprietary Information
    • By agreeing to the CWG IBO Agreement, the IBO acknowledges that business reports, lists
      of Customer and IBO names and contact information and any other information, which
      contain financial, technical or other information both written or otherwise circulated
      by CWG or pertaining to the business of CWG (collectively, “Reports”), are confidential
      and proprietary information and trade secrets belonging to CWG.
  • 12.3 Obligation of Confidentiality
    • During the term of the CWG IBO Agreement and for a period of one (1) year after the
      termination or expiration of the IBO Agreement between the IBO and CWG, the IBO shall
      not;
    • Use the information in the Reports to compete with CWG or for any purpose other than
      promoting his or her CWG business;
    • Use or disclose to any person or entity any confidential information contained in the
      reports, including the replication of the genealogy in another network marketing
      company.
  • 12.4 Breach and Remedies
    • The IBO acknowledges that such proprietary information is of such character as to render
      it unique and that disclosure or use thereof in violation of this provision will result
      in irreparable damage to CWG and to independent CWG businesses. CWG and its IBOs will be
      entitled to injunctive relief or to recover damages against any IBO who violates this
      provision in any action to enforce its rights under this section. The prevailing party
      shall be entitled to an award of lawyer’s fees, court costs and expenses.
  • 12.5 Return of Materials
    • Upon demand by CWG, any current or former IBO will return the original and all copies of
      all “Reports” to CWG together with any CWG confidential information in such person’s
      possession.
  • 13.1 PRIVACY POLICY
  • 13.2 Introduction
    • This Privacy Policy is to ensure that all Customers and IBOs understand and adhere to
      the basic principles of confidentiality. Without limiting the terms of this section 7.0,
      all IBOs must comply with applicable privacy laws governing the collection, use and
      disclosure of Customer and fellow IBO information.
  • 13.3 Expectation of Privacy
    • CWG recognizes and respects the importance its Customers and IBOs place on the privacy
      of their financial and personal information. CWG will make reasonable efforts to
      safeguard the privacy of, and maintain the confidentiality of its Customers’, and IBOs’
      financial and account information and nonpublic personal information.
    • By entering into the IBO Agreement, an IBO or Customer authorizes CWG to disclose his or
      her name and contact information to upline IBOs solely for activities related to the
      furtherance of the CWG business. An IBO hereby agrees to maintain the confidentiality
      and security of such information and to use it solely for the purpose of supporting and
      servicing his or her downline organization and conducting the CWG business.
  • 13.4 Employee Access to Information
    • CWG limits the number of employees who have access to Customer’s and IBOs’ nonpublic
      personal information.
  • 13.5 Restrictions on the Disclosure of Account Information
    • CWG will not share non-public personal information or financial information about
      current or former Customers or IBOs with third parties, except as permitted or required
      by laws and regulations, court orders, or to serve the Customers’, or IBOs’ interests or
      to enforce its rights or obligations under these Policies and Procedures, or IBO’s
      Agreement or with written permission from the accountholder on file.
  • 14.1 ADVERTISING, PROMOTIONAL MATERIAL, USE OF COMPANY NAMES AND TRADEMARKS
  • 14.2 Labeling, Packaging, and Displaying Services
    • An IBO and/or Customer may not re-label, or alter labels, electronically or otherwise
      any CWG service, information, materials or program(s) in any way. CWG Services must only
      be sold through the CWG ecosystem of replicated websites, hosted on CWG servers. Such
      re-labeling violates federal and regulatory laws, which may result in criminal or civil
      penalties or liability.
    • An IBO shall not cause any CWG service or any CWG trade name to be sold or displayed in
      retail establishments except;
        • Where the retail establishment is owned or managed by the CWG IBO and the
          establishment does not exceed $1 million in annual gross revenue, and there are
          five (5) or fewer establishments under common ownership of management.
    • An IBO may sell CWG Services and display the CWG trade name at any appropriate display
      booth (such as trade shows, expositions, conferences etc.) with the express written
      consent of CWG.
        • An IBO or Customer is prohibited to sell CWG Services and display the CWG trade
          name, trademark or service mark at any kiosk or booth located in any retail
          establishment, such as a mall or retail facility.
        • CWG reserves the right to refuse authorization to participate at any function
          that it does not deem a suitable forum for the promotion of its Services and
          services, or the CWG opportunity.
  • 14.3 Use of Company Names and Protected Materials
    • An IBO must safeguard and promote the good reputation of CWG and the Services it
      markets. The marketing and promotion of CWG, the CWG opportunity, the Compensation Plan,
      and CWG Services will be consistent with the public interest, and must avoid all
      discourteous, deceptive, misleading, unethical or immoral conduct and practices.
    • All promotional materials supplied or created by CWG must be used in their original form
      and cannot be changed, amended or altered, except with prior written approval from the
      CWG Compliance Team.
    • The name of CWG, each of its service names and other names that have been adopted by
      CWG, in connection with its business are proprietary trade names, trademarks and service
      marks of CWG. As such, these marks are of great value to CWG and are supplied to IBOs
      for their use only in an expressly authorized manner.
    • An IBO’s use of the name “CWG” is restricted to protect CWG proprietary rights, ensuring
      that the CWG protected names will not be lost or compromised by unauthorized use. Use of
      the CWG name on any item not produced by CWG is prohibited except as follows:
        • [IBO’s name] Independent CWG IBO or CWG Independent Business Owner.
        • [IBO’s name] Independent IBO of CWG Services.
    • Further procedures relating to the use of the CWG name are as follows:
        • All stationary (i.e. letterhead, envelopes, and business cards) bearing the CWG
          name or logo intended for use by the CWG IBO must be submitted via email to the
          CWG Compliance Team for approval. Submit to: [email protected].
        • CWG IBOs may list “Independent CWG IBO” in the white pages of the telephone
          directory under his or her own name.
        • CWG IBOs may not use the name CWG or CWG in answering his or her telephone,
          creating a voice message or using an answering service, such as to give the
          impression to the caller that they have reached the corporate office. They may
          state, “Independent CWG IBO.”
    • Certain photos and graphic images used by CWG in its advertising, packaging, and
      websites are the result of paid contracts with outside vendors that do not extend to
      IBOs. If an IBO wants to use these photos or graphic images, they must negotiate
      individual contracts with the vendors for a fee.
    • An IBO shall not appear on or make use of television or radio or make use of any other
      media to promote or discuss CWG or its programs, services without prior written
      permission from the CWG Compliance Team.
        • An IBO may not produce for sale or distribution any Company event or speech, nor
          may an IBO reproduce CWG audio or video clips for sale or for personal use
          without prior written permission from the CWG Compliance Where professional
          services are the primary source of revenue and the service sales are secondary
          (e.g., d’s offices, clinics, health clubs, spas and beauty salons); Team.
    • CWG reserves the right to rescind its prior approval of any sales aid or promotional
      materials to comply with changing laws and regulations and may request the removal from
      the marketplace of such materials without financial obligation to the affected IBO.
    • An IBO shall not promote non-CWG Services or services in conjunction with CWG Services
      or services on the same social media site or same advertisement without prior approval
      from CWG Compliance Team.
    • Claims (which include personal testimonials) of any Services offered by CWG may not be
      made except those contained in official CWG literature. In particular, no IBO may make
      any claim that CWG Services guarantee financial, of investment growth, profits, or any
      other financial team seen as a purported or guarantee of return on investment. Such
      statements can be perceived as investment claims. Not only do such claims violate CWG
      policies, but they also potentially violate federal and provincial laws and regulations.
  • 14.4 Faxes and E-mail – Limitations
    • Except as provided in this section, an IBO may not use or transmit unsolicited email,
      mass email distribution, other commercial electronic messages or “spamming” that
      advertises or promotes the operation of his or her CWG business. The exceptions are;
        • E-mailing any person who has given prior permission or invitation;
        • E-mailing any person with whom the IBO has established a current business or
          personal relationship.
    • In all states or U.S. or International territories where prohibited by law, an IBO may
      not transmit, or cause to be transmitted through a third party, (by telephone,
      facsimile, computer or other device), an unsolicited advertisement to any equipment,
      which has the capacity to transcribe text or images from an electronic signal received
      over a regular telephone line, cable line, ISDN, T1 or any other signal carrying device,
      except as set forth in this section.
    • All e-mail or computer broadcasted documents subject to this provision shall include
      each of the following;
        • A clear and obvious identification that the fax or e-mail message is an
          advertisement or solicitation. The words “advertisement” or “solicitation”
          should appear in the subject line of the message;
        • A clear return path or routing information;
        • The use of legal and proper domain name;
        • A clear and obvious notice of the opportunity to decline to receive further
          commercial facsimile or e-mail messages from the sender;
        • Unsubscribe or opt-out instructions should be the very first text in the body of
          the message box in the same size text as the majority of the message;
        • The true and correct name of the sender, valid senders fax or e-mail address,
          and a valid sender physical address;
        • The date and time of the transmission;
        • Upon notification by recipient of his or her request not to receive further
          faxed or e-mailed documents, an IBO shall not transmit any further documents to
          that recipient.
    • All e-mail or computer broadcasted documents subject to this provision shall not include
      any of the following;
        • Use of any third-party domain name without permission;
        • Sexually explicit materials.
  • 14.5 Internet and Third-Party Website Restrictions
    • An IBO and/or Customer is prohibited from creating or registering any third-party
      website in order to promote, sell or advertise their CWG business. AN IBO and/or
      Customer is prohibited to use or attempt to register any of CWG’s trade names,
      trademarks, service names, service marks, product names, URLs, advertising phrases, the
      CWG name or any derivative thereof, for any purpose including, but not limited to,
      Internet domain names (URL), third party websites, e-mail addresses, web pages, or
      blogs.
    • An IBO may not sell CWG Services, or offer the Business Opportunity using “online
      auctions,” such as eBay®, Amazon, Etsy or other external retail websites or auction
      sites.
    • Social Media sites may be used to sell or offer to sell CWG Services or services.
      PROFILES AN IBO OR CUSTOMER GENERATES IN ANY SOCIAL COMMUNITY WHERE CWG IS DISCUSSED OR
      MENTIONED MUST CLEARLY IDENTIFY THE IBO AS AN INDEPENDENT CWG IBO, and when An IBO
      and/or Customer participates in those communities, CWG IBOs and/or Customers must avoid
      inappropriate conversations, comments,

      images, video, audio, applications or any other adult, profane, discriminatory or
      vulgar content. The determination of what is inappropriate is at CWG’s sole discretion,
      and offending CWG IBO and/or Customer will be subject to disciplinary action. Banner ads
      and images used on these sites must be current and must come from the CWG approved
      library, official CWG website or social media outlet. If a link is provided, it must
      link to the posting IBO’s Replicated website.

    • Anonymous postings or use of an alias on any Social Media site is prohibited, and
      offending CWG IBOs will be subject to disciplinary action.
    • An CWG BOs and/or Customers may not use blog spam, spamdexing or any other
      mass-replicated methods to leave blog comments. Comments IBOs or Customers create, or
      leave must be useful, unique, relevant and specific to the blog’s article.
    • An IBOs and/or Customers must disclose their full name on all Social Media postings, and
      conspicuously identify themselves as an Independent CWGIBO for CWG. Anonymous postings
      or use of an alias is prohibited.
    • Postings that are false, misleading, or deceptive are prohibited. This includes, but is
      not limited to, false or deceptive postings relating to the CWG income opportunity,
      CWG’s Services and services, and/or your biographical information and credentials.
    • An IBO and/or Customer are personally responsible for their postings and all other
      online activity that relates to CWG. Therefore, even if An IBO does not own or operate a
      blog or Social Media site, if An IBO and/or Customer posts to any such site that relates
      to CWG or which can be traced to CWG, the IBO is responsible for the posting. IBO and/or
      Customer are also responsible for postings which occur on any blog or Social Media site
      that the IBO and/or Customer owns, operates, or controls.
    • As an IBO, it is important to not converse with any person who places a negative post
      against you, other CWG IBOs, or CWG. Report negative posts to CWG at [email protected]. Responding to
      such negative posts often simply fuels a discussion with someone carrying a grudge that
      does not hold themselves to the same high standards as CWG, and therefore damages the
      reputation and goodwill of CWG.
    • The distinction between a Social Media site and a website may not be clear- cut, because
      some Social Media sites are particularly robust, CWG therefore reserves the sole and
      exclusive right to classify certain Social Media sites as third-party websites which are
      herein prohibited.
    • If your CWG business is cancelled for any reason, you must discontinue using the CWG
      name, and all of CWG’s trademarks, trade names, service marks, and other intellectual
      property, and all derivatives of such marks and intellectual property, in any postings
      and all Social Media sites that you utilize. If you post on any Social Media site on
      which you have previously identified

      yourself as an Independent CWGIBO, you must conspicuously disclose that you are no
      longer an Independent CWGIBO.

    • Failure to comply with these Policies for conducting business online may result in the
      IBO losing their right to advertise and market CWG services and CWG’s business
      opportunity online in addition to any other disciplinary action available under the
      Policies and Procedures.
  • 14.6 Advertising and Promotional Materials
    • You may not advertise any CWG Services at a price LESS than the highest company
      published, established retail price of the CWG service and applicable taxes. No special
      enticement advertising is allowed. This includes, but is not limited to, offers of free
      membership, or other such offers that grant advantages beyond those available through
      the Company.
    • Advertising and all forms of communications must adhere to principles of honesty and
      propriety.
    • All advertising, including, but not limited to, print, Internet, computer bulletin
      boards, television, radio, etc., are subject to prior written approval by the CWG
      Compliance Team.
    • All requests for approvals with respect to advertising must be directed in writing to
      the CWG Compliance Team.
    • AN IBO who is currently paid at the Chairman 250 rank may create his or her own ads or
      promotional materials including the development of commercials or infomercials. However,
      all such materials, and any subsequent changes thereto, shall be submitted to the CWG
      Compliance Team for approval.
    • Chairmen 250 are encouraged to work with the Compliance Team prior to the production of
      commercials, infomercials, or websites.
    • CWG reserves the right to rescind its prior approval of submitted advertising or
      promotional materials in order to comply with changing laws and regulations, and may
      require the removal of such advertisements from the marketplace without obligation to
      the affected CWG IBO.
  • 14.7 Testimonial Permission
    • By agreeing to the CWG IBO Agreement, An IBO gives CWG permission to use his or her
      testimonial or image and likeness in corporate sales materials, including but not
      limited to print media, electronic media, audio and video. In consideration of being
      allowed to participate in the CWG Business Opportunity, An IBO waives any right to be
      compensated for the use of his or her testimonial or image and likeness even though CWG
      may be paid for items or sales materials containing such image and likeness, and
      represents that any testimonial represents CWG IBO’s current, original, honest
      opinion,
      thoughts, beliefs, findings or experiences, based on IBO’s actual
      experience with CWG and any stated use of CWG Services and/or services, and agrees to
      notify IBO immediately of any changes in the views expressed in the testimonial. In some
      cases, An IBO’s testimonial may appear in another CWG IBO’s advertising materials. If an
      IBO does not wish to participate in CWG sales and marketing materials, he or she should
      provide a written notice to the CWG Compliance Team to ensure that his or her
      testimonial or image and likeness will not be used in any corporate materials, corporate
      recognition pieces, advertising or recordings of annual events.
  • 14.8 Telemarketing – Limitations
    • AN IBO must not engage in telemarketing in relation to the operation of the CWG IBO’s
      CWG business. The term “telemarketing” means the placing of one or more telephone calls
      or facsimile transmissions to an individual or entity to induce the purchase of CWG
      Services or to recruit them for the CWG opportunity.
    • ; The federal government administers the Unsolicited Telecommunication Rules and
      operates a national Do-Not-Call registry that requires businesses to refrain from
      calling phone numbers listed on the national “Do-Not-Call” list (DNCL) and or people who
      tell the caller directly not to call/fax in the future.
    • While an IBO may not consider himself or herself a “telemarketer” in the traditional
      sense, these regulations broadly define the term “telemarketer” and “telemarketing” so
      that the unintentional action of calling someone whose telephone number is listed on the
      Federal “Do Not Call” registry could cause the IBO to violate the law. These regulations
      must not be taken lightly, as they carry significant penalties.
    • “Cold calls” or unsolicited calls/faxes made to prospective Customers or IBOs in order
      to promote CWG Services, services or the CWG opportunity is considered telemarketing and
      is prohibited.
    • Exceptions to Telemarketing Regulations
    • AN IBO may place telephone calls or faxes to prospective Customers, or IBOs under the
      following limited situations:
        • If the IBO has an established current business relationship with the prospect;
        • In response to the prospect’s personal inquiry or application regarding a
          product or service offered by the CWGIBO, within 3 months immediately before the
          date of such a call/fax;
        • If the IBO receives written and signed permission from the prospect authorizing
          the IBO to call/fax;
        • If the call/fax is to family members, personal friends, and
          acquaintances.
          However, if an IBO makes a habit of collecting business cards from everyone
          he/she meets and subsequently calls/faxes them, the federal government may
          consider this a form of telemarketing that is not subject to this exemption;
        • CWG IBOs engaged in calling “acquaintances,” must make such calls/faxes on an
          occasional basis only and not as a routine practice.
    • AN IBO shall not use automatic telephone dialing systems in the operation of his or her
      CWG businesses.
    • Failure to abide by CWG policies or regulations as set forth by the federal government
      regarding telemarketing may lead to sanctions against the CWG IBO’s position, up to and
      including termination of the position.
    • By signing the CWG IBO Agreement, or by accepting commissions, other payments or awards
      from CWG, an IBO gives permission to CWG and other CWG IBOs to contact them as permitted
      under the Federal Do Not Call regulations.
    • In the event An IBO violates this section, CWG reserves the right to institute legal
      proceedings to obtain monetary or equitable relief.
  • 15.1 Circle of Wealth Group
  • 15.2 Circle of Wealth Group Policy
    • AN IBO is authorized to sell CWG services, to Customers and CWG IBOs only in the
      countries in which CWG is authorized to conduct business, according to the Policies and
      Procedures of each country. CWG IBOs may not sell services in any country where CWG
      services have not received applicable government authorization or approval.
    • AN IBO may not, in any unauthorized country, conduct sales, enrollment or training
      meetings, enroll or attempt to enroll potential Customers, or IBOs, nor conduct any
      other activity for the purpose of selling CWG services, establishing a sales
      organization, or promoting the CWG business opportunity.
  • 16.0 CWG GLOSSARY OF TERMS
    • ACTIVE IBO: AN IBO who is in good standing with respect to the
      Agreement and who satisfies the minimum sales volume requirements, as set forth in the
      Compensation Plan, to ensure that they are eligible to receive bonuses and commissions.
    • AGREEMENT: The contract between CWG and each CWG IBO and
      Customer; includes the IBO Agreement, the CWG Policies and Procedures, and the CWG
      Compensation Plan, all in their current form and as amended by CWG in its sole

      discretion in accordance with the terms hereof. These documents are collectively
      referred to as the “Agreement.”

    • CANCEL:The termination of An IBO’s business. Cancellation may be
      either voluntary, involuntary, or through non-renewal.
    • COMPENSATION PLAN:The guidelines and referenced literature for
      describing how IBOs can generate commissions and bonuses
    • CUSTOMER: A Customer who purchases CWG Services and does not
      engage in building a business or retailing product.
    • IBO: AN IBO who enrolls a Customer, or another IBO into the
      Company, and is listed as the Sponsor on the IBO Agreement. The act of enrolling others
      and training them to become IBOs is called “Sponsoring.”
      *Note: Any reference to “personally
      enrolling/sponsoring” herein is simply descriptive of the method of building a
      community of IBOs, ie. personally, enrolling other participants into the Plan.
      The phrase is not intended to imply any connection between the simple act of
      recruitment, sponsorship, or enrollment, and payment of
      compensation.
    • IBO’S/IBO’S WALLET: Is a secure site that manages CWG IBO’s commissions.
    • SPONSOR*: AN IBO who enrolls a Customer, Retailer, or another
      CWG IBO into the Company, and is listed as the Sponsor on the IBO Agreement. The act of
      enrolling others and training them to become CWG IBOs is called “sponsoring.”
      *Note: Any reference to “personally
      enrolling/sponsoring” herein is simply descriptive of the method of building a
      community of IBOs, ie. personally enrolling other participants into the Plan.
      The phrase is not intended to imply any connection between the simple act of
      recruitment, sponsorship, or enrollment, and payment of
      compensation.
    • IBO: An individual or entity who actively promotes, markets and
      sells CWG Services for profit and who actively seeks and recruits others to do the same
      in accordance with the Agreement.
    • LINE OF SPONSORSHIP (LOS): A report generated by CWG that
      provides critical data relating to the identities of IBOs, sales information, and
      enrollment activity of each CWG IBO’s organization. This report contains confidential
      and trade secret information which is proprietary to CWG.
    • ORGANIZATION: The Customers and CWG IBO placed below a
      particular IBO
    • OFFICIAL CWGMATERIAL: Literature, audio or video tapes, and/or
      any other materials developed, printed, published, or distributed by CWG to IBO and
      Customers.
    • PLACEMENT: Your position inside your Sponsor’s organization.
    • RECRUIT: For purposes of the Agreement, the term “Recruit”
      means the actual or attempted solicitation, enrollment, encouragement, or effort to
      influence in any
      other way, either directly, indirectly, or through a third party,
      another CWGIBO or Customer to enroll or participate in another multilevel marketing,
      network marketing, or direct sales opportunity.
    • UPLINE: This term refers to the CWG IBO or IBOs above a
      particular CWG IBO or Sponsor in a sponsorship line up to the Company. It is the line of
      sponsors that links any particular IBO to the Company.