Network Management Policy 

Effective Date: May 1, 2024 

Anthem Connect, has adopted the following network management practices, performance characteristics, and commercial terms and conditions (this “Network Management Policy”) for its broadband Internet access services in compliance with the regulations set forth by the Federal Communications Commission (“FCC”). This policy should be read in conjunction with, and does not replace or supersede, the Company’s other legal policies, including but not limited to the Terms & Conditions, Acceptable Use, Fair Use Policy, and the Privacy Policy, available on the Company’s website. 

Effective Date: May 1, 2024 

ACU Global LLC, dba Anthem Connect, (FCC FRN Registration Number 0035517085) has adopted the following network management practices, performance characteristics, and commercial terms and conditions (this “Network Management Policy”) for its broadband Internet access services in compliance with the regulations set forth by the Federal Communications Commission (“FCC”). This policy should be read in conjunction with, and does not replace or supersede, the Company’s other legal policies, including but not limited to the Terms & Conditions, Acceptable Use, Fair Use Policy, and the Privacy Policy, available on the Company’s website. 

This Network Management Policy may be amended at any time in the sole discretion of the Company. The most recent version of this Network Management Policy will be posted on the Company’s website. 

I. NETWORK MANAGEMENT PRACTICES 

Anthem Connect participates as a provider on multiple Open Access Networks.  Open Access Networks are owned by an Infrastructure company, or a municipality (Provider).  The Provider is responsible for bringing the Internet to the customer premises and providing Internet Services.  Anthem Connect is responsible for providing customer support for their home network and is a liaison to communicate with the Provider partner regarding outages, service, and support.  

Anthem Connect, (the Company), and their Internet Infrastructure Provider partners, manages the network with the goal of providing the best practicable broadband Internet experience to all of its customers (referred to generally herein as the “Services”). Within its resources, it tries to deploy and maintain adequate capacity and facilities within its own network and to acquire enough capacity or facilities via open access network partnerships, to connect customers with the Internet. The Company and its staff use their best efforts to monitor, address and support services provided (but do not guarantee that they can prevent) the effects of spam, viruses, security attacks, network congestion, and other phenomena that can degrade the service of affected customers. 

The Company and their Internet Infrastructure Provider partners use various tools and techniques to manage the network. By using effective network management practices, the Company and the Providers can optimize customers’ overall broadband Internet service experiences. 

1. Blocking: The Company and/or the Providers do not block any lawful content, applications, devices, and/or non-harmful devices, and does not discriminate in transmitting lawful network traffic. 

2. Throttling: The Company and/or the Providers do not throttle, impair or degrade lawful internet traffic, except as provided below in accordance with Congestion Management Practices in Paragraph 5. 

3. Affiliated Prioritization: The Company and/or the Providers do not prioritize its own content, application, services, or devices, or those of its affiliates. 

4. Paid Prioritization: The Company and/or the Providers do not use or demand “pay-for-priority” or similar arrangements that directly or indirectly favor some traffic over other traffic. 

5. Congestion Management Practices: During times of congestion, the Company and or the Providers use congestion management tools to optimize the overall customer experience. Specifically, the Company and/or the Providers monitor and proactively reinforce the network with additional capacity where possible. When congestion is identified, beyond the Company’s and/or the Providers network capacity, they may limit or disconnect a customer’s use of the Services if a customer is excessively using the Services. It is anticipated that very small fractions of customers will excessively use the Services, such that the Company and/or the Providers must limit the customer’s use. However, the Company is committed to providing optimal Services for all customers, so some limitations may occur. The Company does not place a specific numerical cap on any customer’s data usage—limits for congestion management will take place on a case-by-case basis. See the Acceptable Use Policy for more details. 

6. Application-Specific Behavior Practices The Company and/or the Providers do not favor or inhibit certain applications or classes of applications, while reserving the right to block applications as necessary to protect the network and its customers. Customers may use any lawful and commercially available application which they desire on the Company’s network, including any customer-developed or modified application, unless there is a reasonable belief that such applications will cause harm to the Company’s and/or the Providers network. 

7. Device Attachment Rules The Company and/or the Providers do not have any approval procedures that must be satisfied before a device can be connected to its network. Customers may use any lawful, compatible, type-accepted (if necessary) and commercially available device which they desire on the network, so long as such device does not harm the network. The Company and/or the Providers undertake no obligation to monitor or investigate the lawfulness of the devices used by its customers. Customers may occasionally develop their own devices or modify commercially available devices. The Company and/or the Providers will not prohibit the use of lawful customer-developed or modified devices unless there is a reasonable belief that such devices will cause harm to its network. The Company and/or the Providers do not guarantee the functionality of any devices selected by the customer. 

8. Security Practices The Company and/or the Providers do not normally monitor the traffic of its customers. It undertakes no obligation to monitor or protect such customer traffic from spam, viruses, denial-of-service attacks, or other malicious, unlawful or unwanted activities. The Company recognizes that customers can purchase spam filtering and anti-virus software from commercial vendors to meet their needs. The Company may sometimes offer anti-spam and/or anti-virus software or services to customers who want to purchase them from the Company. When offered, these software or services will be described and priced in other sections of this website. Customers are free to obtain anti-spam and/or anti-virus software or services from any source they desire, if such software or services do not disrupt or degrade the traffic of other customers of the Company or harm the Providers network. A customer that is subjected to a denial-of-service attack, or similar malicious, unlawful, or unwanted activity, must notify the Company as soon as possible. The Company will work with the customer, other service providers, federal and state regulators, and/or law enforcement to determine the source of such activity, and to take appropriate, and technically and economically reasonable efforts to address the matter. The Company employs commercially appropriate security procedures to protect its network and its customer records from unauthorized access by third parties. The Company does not guarantee that it can protect customers from any and/or all security breaches. 

The Company reserves the right to block any application or device based on a threat to the network or other customers. 

These security measures are not designed to prevent or restrict any customer’s use of the Services, so long as the customer’s activities are not a threat to the network or any other customers. 

II. Performance Characteristics 

Description of Services: The service and performance characteristics of the Company’s broadband Internet access services can be found in the service offering portions of this website. The Company offers different tiers of service at different prices and changes these sometimes. The Company also may offer custom solutions for customers. Actual access speeds and latency of the Services are impacted by the length, capacity and congestion of Middle Mile transport facilities (between the Company’s servers, the Providers service area and Internet nodes), as well as the characteristic of the Company’s own network. The Company offers a speed test site to any user or customer which can be found on the Company’s website. The actual speed that a customer will experience while using the Services depends on a variety of conditions, many of which are beyond the control of the Company. Internet speed claims contained in the Company’s policies, advertisements, and posted on the Company’s website, represent only the maximum speed capabilities and may vary based on many factors. Actual internet speeds may vary and are not guaranteed. The Company’s service is suitable for real-time applications. The speed tier a customer subscribes to will impact the efficiency of the real-time applications. 

Impact of Specialized Services: The Company does not offer specialized services to end-users. 

III. Commercial Terms 

The commercial terms and conditions of the Company’s broadband Internet access services are contained in greater detail in the Company’s Terms & Conditions, found on the Company’s website. 

Pricing: The Company offers different tiers and levels of service at different prices, and changes these from time to time. To see the Company’s current promotions and pricing on broadband Internet service, visit the Company’s website, or contact a sales representative at (943) 230-3099. The Company is willing to consider and negotiate prices for customized additional network services requested by specific customers or edge service providers if such services can be designed, developed and furnished in a commercially reasonable manner. If and when such customized services are developed and furnished, the Company reserves the right to adapt and provide them to other  
customers on a non-discriminatory basis so long as such subsequent provision does not entail disclosure of proprietary or confidential information of the initial customer. 
 
If a customer enters into a service agreement with the Company for the Services for a defined term, and the customer desires to terminate the agreement prior to the expiration of that term, the Company may charge a reasonable early termination fee if such fee is indicated in the service agreement. Unless otherwise provided, the termination fee will be equal to 50% of the monthly plan’s price multiplied by the number of remaining months in the agreement, or the price of installation that was waived at  
time of sign-up, whichever is less. 

The Company’s Services are priced on a flat-fee basis, plus taxes and any applicable fees. The Company does not charge a usage-based fee for the Services. 

Privacy Policies: The Company’s full Privacy Policy can be found on the Company’s Website. The Company does not collect, store or use traffic information to profile its customers in order to sell additional services to them, or for similar non-network management purposes. 
 
The Company reserves the right to monitor bandwidth, usage, transmissions, and content for the purposes of protecting the integrity of the network and other customers through reasonable network management practices. Any network traffic, activity, performance information, and equipment information monitored or collected by the Company is done for the sole purpose of reasonable network management purposes. The Company will provide to law enforcement with available traffic information legally requested pursuant to the procedures of the Communications Assistance for Law Enforcement Act (“CALEA”), the Foreign Intelligence Surveillance Act (“FISA”) or other applicable national security or criminal statutes. 
 
The Company’s network management practices are not intended or implemented to block consumers from accessing content and applications of their choice or discriminate against or in favor of certain network traffic. 

Redress Options: Questions and complaints regarding the foregoing matters contained in this Network Management Policy should be addressed to Customer Relations at cr@anthemconnectus.com.   

I. NETWORK MANAGEMENT PRACTICES 

Anthem Connect participates as a provider on multiple Open Access Networks.  Open Access Networks are owned by an Infrastructure company, or a municipality (Provider).  The Provider is responsible for bringing the Internet to the customer premises and providing Internet Services.  Anthem Connect is responsible for providing customer support for their home network and is a liaison to communicate with the Provider partner regarding outages, service, and support.  

Anthem Connect, (the Company), and their Internet Infrastructure Provider partners, manages the network with the goal of providing the best practicable broadband Internet experience to all of its customers (referred to generally herein as the “Services”). Within its resources, it tries to deploy and maintain adequate capacity and facilities within its own network and to acquire enough capacity or facilities via open access network partnerships, to connect customers with the Internet. The Company and its staff use their best efforts to monitor, address and support services provided (but do not guarantee that they can prevent) the effects of spam, viruses, security attacks, network congestion, and other phenomena that can degrade the service of affected customers. 

The Company and their Internet Infrastructure Provider partners use various tools and techniques to manage the network. By using effective network management practices, the Company and the Providers can optimize customers’ overall broadband Internet service experiences. 

1. Blocking: The Company and/or the Providers do not block any lawful content, applications, devices, and/or non-harmful devices, and does not discriminate in transmitting lawful network traffic. 

2. Throttling: The Company and/or the Providers do not throttle, impair or degrade lawful internet traffic, except as provided below in accordance with Congestion Management Practices in Paragraph 5. 

3. Affiliated Prioritization: The Company and/or the Providers do not prioritize its own content, application, services, or devices, or those of its affiliates. 

4. Paid Prioritization: The Company and/or the Providers do not use or demand “pay-for-priority” or similar arrangements that directly or indirectly favor some traffic over other traffic. 

5. Congestion Management Practices: During times of congestion, the Company and or the Providers use congestion management tools to optimize the overall customer experience. Specifically, the Company and/or the Providers monitor and proactively reinforce the network with additional capacity where possible. When congestion is identified, beyond the Company’s and/or the Providers network capacity, they may limit or disconnect a customer’s use of the Services if a customer is excessively using the Services. It is anticipated that very small fractions of customers will excessively use the Services, such that the Company and/or the Providers must limit the customer’s use. However, the Company is committed to providing optimal Services for all customers, so some limitations may occur. The Company does not place a specific numerical cap on any customer’s data usage—limits for congestion management will take place on a case-by-case basis. See the Acceptable Use Policy for more details. 

6. Application-Specific Behavior Practices The Company and/or the Providers do not favor or inhibit certain applications or classes of applications, while reserving the right to block applications as necessary to protect the network and its customers. Customers may use any lawful and commercially available application which they desire on the Company’s network, including any customer-developed or modified application, unless there is a reasonable belief that such applications will cause harm to the Company’s and/or the Providers network. 

7. Device Attachment Rules The Company and/or the Providers do not have any approval procedures that must be satisfied before a device can be connected to its network. Customers may use any lawful, compatible, type-accepted (if necessary) and commercially available device which they desire on the network, so long as such device does not harm the network. The Company and/or the Providers undertake no obligation to monitor or investigate the lawfulness of the devices used by its customers. Customers may occasionally develop their own devices or modify commercially available devices. The Company and/or the Providers will not prohibit the use of lawful customer-developed or modified devices unless there is a reasonable belief that such devices will cause harm to its network. The Company and/or the Providers do not guarantee the functionality of any devices selected by the customer. 

8. Security Practices The Company and/or the Providers do not normally monitor the traffic of its customers. It undertakes no obligation to monitor or protect such customer traffic from spam, viruses, denial-of-service attacks, or other malicious, unlawful or unwanted activities. The Company recognizes that customers can purchase spam filtering and anti-virus software from commercial vendors to meet their needs. The Company may sometimes offer anti-spam and/or anti-virus software or services to customers who want to purchase them from the Company. When offered, these software or services will be described and priced in other sections of this website. Customers are free to obtain anti-spam and/or anti-virus software or services from any source they desire, if such software or services do not disrupt or degrade the traffic of other customers of the Company or harm the Providers network. A customer that is subjected to a denial-of-service attack, or similar malicious, unlawful, or unwanted activity, must notify the Company as soon as possible. The Company will work with the customer, other service providers, federal and state regulators, and/or law enforcement to determine the source of such activity, and to take appropriate, and technically and economically reasonable efforts to address the matter. The Company employs commercially appropriate security procedures to protect its network and its customer records from unauthorized access by third parties. The Company does not guarantee that it can protect customers from any and/or all security breaches. 

The Company reserves the right to block any application or device based on a threat to the network or other customers. 

These security measures are not designed to prevent or restrict any customer’s use of the Services, so long as the customer’s activities are not a threat to the network or any other customers. 

II. Performance Characteristics 

Description of Services: The service and performance characteristics of the Company’s broadband Internet access services can be found in the service offering portions of this website. The Company offers different tiers of service at different prices and changes these sometimes. The Company also may offer custom solutions for customers. Actual access speeds and latency of the Services are impacted by the length, capacity and congestion of Middle Mile transport facilities (between the Company’s servers, the Providers service area and Internet nodes), as well as the characteristic of the Company’s own network. The Company offers a speed test site to any user or customer which can be found on the Company’s website. The actual speed that a customer will experience while using the Services depends on a variety of conditions, many of which are beyond the control of the Company. Internet speed claims contained in the Company’s policies, advertisements, and posted on the Company’s website, represent only the maximum speed capabilities and may vary based on many factors. Actual internet speeds may vary and are not guaranteed. The Company’s service is suitable for real-time applications. The speed tier a customer subscribes to will impact the efficiency of the real-time applications. 

Impact of Specialized Services: The Company does not offer specialized services to end-users. 

III. Commercial Terms 

The commercial terms and conditions of the Company’s broadband Internet access services are contained in greater detail in the Company’s Terms & Conditions, found on the Company’s website. 

Pricing: The Company offers different tiers and levels of service at different prices, and changes these from time to time. To see the Company’s current promotions and pricing on broadband Internet service, visit the Company’s website, or contact a sales representative at (943) 230-3099. The Company is willing to consider and negotiate prices for customized additional network services requested by specific customers or edge service providers if such services can be designed, developed and furnished in a commercially reasonable manner. If and when such customized services are developed and furnished, the Company reserves the right to adapt and provide them to other  
customers on a non-discriminatory basis so long as such subsequent provision does not entail disclosure of proprietary or confidential information of the initial customer. 
 
If a customer enters into a service agreement with the Company for the Services for a defined term, and the customer desires to terminate the agreement prior to the expiration of that term, the Company may charge a reasonable early termination fee if such fee is indicated in the service agreement. Unless otherwise provided, the termination fee will be equal to 50% of the monthly plan’s price multiplied by the number of remaining months in the agreement, or the price of installation that was waived at  
time of sign-up, whichever is less. 

The Company’s Services are priced on a flat-fee basis, plus taxes and any applicable fees. The Company does not charge a usage-based fee for the Services. 

Privacy Policies: The Company’s full Privacy Policy can be found on the Company’s Website. The Company does not collect, store or use traffic information to profile its customers in order to sell additional services to them, or for similar non-network management purposes. 
 
The Company reserves the right to monitor bandwidth, usage, transmissions, and content for the purposes of protecting the integrity of the network and other customers through reasonable network management practices. Any network traffic, activity, performance information, and equipment information monitored or collected by the Company is done for the sole purpose of reasonable network management purposes. The Company will provide to law enforcement with available traffic information legally requested pursuant to the procedures of the Communications Assistance for Law Enforcement Act (“CALEA”), the Foreign Intelligence Surveillance Act (“FISA”) or other applicable national security or criminal statutes. 
 
The Company’s network management practices are not intended or implemented to block consumers from accessing content and applications of their choice or discriminate against or in favor of certain network traffic. 

Redress Options: Questions and complaints regarding the foregoing matters contained in this Network Management Policy should be addressed to Customer Relations at cr@anthemconnectus.com.