Policy & Procedures Manual

1. Company Mission

Pompano Beach Realty Corporation ("Brokerage" or "PBRC") is committed to delivering real estate services with professionalism, transparency, compliance, integrity, and lawful supervision. This Manual establishes minimum standards governing all real estate activities conducted under the Brokerage.

2. Professional Standards

All brokers, broker associates, sales associates, independent contractors, assistants, employees, and affiliated personnel must:

• Conduct business honestly, ethically, competently, and professionally;
• Comply with Florida law, Florida Real Estate Commission ("FREC") rules, MLS rules, Fair Housing laws, applicable REALTOR(R) standards, and all applicable federal, state, county, and municipal requirements;
• Protect clients' and customers' lawful interests and confidential information;
• Maintain complete, accurate, and timely records;
• Avoid fraud, misrepresentation, concealment, negligence, deceptive conduct, and the unauthorized practice of law;
• Promptly disclose material compliance or legal concerns to the Broker; and
• Protect the reputation, licenses, contracts, property, systems, and legitimate business interests of PBRC.

3. Receipt, Notice, and Agreement to Brokerage Policies

Access to this Manual and continued affiliation with PBRC constitute notice of the Brokerage's operating rules. By affiliating with, remaining registered under, conducting business through, using the systems of, receiving compensation from, or representing PBRC, affiliated personnel agree to comply with this Manual and lawful Broker directives to the fullest extent permitted by law.

PBRC may require a separate written or electronic acknowledgment whenever the Broker determines that additional proof of acceptance is appropriate. No automatic-acceptance provision shall replace a signature where applicable law requires a signed writing.

4. Independent Contractor Status

Unless a separate written agreement states otherwise, affiliated sales associates and broker associates operate as independent contractors and not as employees. They are responsible for their own taxes, licensing, continuing education, professional dues, transportation, equipment, marketing, insurance, and business expenses.

Independent-contractor status does not reduce the Brokerage's lawful supervisory authority or the agent's obligation to comply with this Manual, applicable law, MLS rules, and Broker instructions.

5. Agent Responsibility, Indemnification, and Brokerage Protection

Each affiliated licensee is responsible for the licensee's own acts, omissions, statements, representations, advertisements, disclosures, negotiations, communications, documents, technology use, access to property, supervision of assistants, and professional services.

PBRC is not responsible for unauthorized conduct, conduct outside the scope of the agent's authority, or conduct contrary to law, this Manual, an applicable agreement, or a lawful Broker directive, except to the extent responsibility may not lawfully be disclaimed.

To the fullest extent permitted by law, each agent shall defend, indemnify, reimburse, and hold harmless PBRC and its Broker, officers, directors, shareholders, employees, and authorized representatives from claims, demands, investigations, administrative proceedings, lawsuits, arbitration proceedings, judgments, settlements, fines, penalties, losses, damages, chargebacks, deductibles, costs, and reasonable attorneys' fees arising from or relating to the agent's:

• Negligence, willful misconduct, fraud, misrepresentation, concealment, or unauthorized acts;
• Advertising, copyright, trademark, privacy, Fair Housing, antitrust, telemarketing, or data-security violations;
• Failure to make a required disclosure or deliver a required document;
• Unauthorized legal, tax, title, zoning, permitting, inspection, insurance, lending, or environmental advice;
• Violation of a contract, MLS rule, association rule, law, regulation, or Broker directive;
• Property damage, personal injury, security incident, lockbox misuse, or unauthorized property access;
• Use or supervision of an assistant, vendor, photographer, contractor, or other third party; or
• Any other act or omission attributable to the agent.

The agent's indemnification obligation applies only to the extent caused by or attributable to the agent and does not waive any nonwaivable duty imposed upon PBRC or the Broker by law. This section survives termination of affiliation.

6. Licensing and Compliance

• Maintain an active Florida real estate license in good standing;
• Complete all education, renewal, and licensing requirements before applicable deadlines;
• Immediately report complaints, investigations, subpoenas, lawsuits, arrests or criminal charges relevant to licensure, regulatory inquiries, license restrictions, and disciplinary matters;
• Conduct licensed activity only through PBRC while registered with PBRC;
• Submit requested compliance records promptly; and
• Stop conducting licensed activity immediately if the license becomes inactive, suspended, expired, or otherwise unauthorized.

7. Advertising and Marketing

All advertising must be truthful, accurate, current, properly authorized, and compliant with Florida law, FREC rules, Fair Housing requirements, MLS rules, platform rules, and Broker directives. Brokerage identification must appear whenever required.

This policy applies to websites, domains, social media, email, text messages, signs, flyers, business cards, videos, online profiles, paid advertisements, listing descriptions, MLS remarks, direct mail, and all other public communications.

The Broker may require prior approval, correction, suspension, or removal of any advertisement. Use of PBRC's name, logo, phone numbers, domains, listings, data, or reputation without authorization is prohibited.

8. Photography, Video, and Media

Strict Prohibition on Third-Party Photos

PBRC agents may not use third-party photographs under any circumstance unless the specific use is supported by documented written ownership, assignment, or licensing rights and is approved in writing by the Broker before publication.

The same rule applies to videos, renderings, floor plans, graphics, screenshots, logos, music, virtual tours, drone media, illustrations, and other protected content.

Prohibited sources include Google Images, Zillow, Realtor.com, MLS screenshots or downloads not authorized for reuse, builder or developer websites, competing brokerage websites, social media, prior listing media, photographers' portfolios, unlicensed stock libraries, and any other source for which the agent cannot document lawful rights.

Permitted Sources

• Original media created by the agent, provided the agent owns all necessary rights;
• Professional media commissioned under a written agreement granting the required rights to the seller, agent, or Brokerage;
• Media supplied by an owner with written confirmation that the owner possesses and grants the required rights;
• Commercial stock media supported by a license permitting the exact intended use; and
• Brokerage-owned material approved by the Broker.

Documentation and Violations

Agents must retain licenses, releases, photographer agreements, owner authorizations, invoices, and other evidence of rights. Unauthorized media must be removed immediately upon instruction. The responsible agent is liable, to the fullest extent permitted by law, for claims, settlements, judgments, licensing charges, attorneys' fees, costs, and other losses caused by unauthorized use. Violations may result in suspension or termination.

9. Social Media

Real estate-related social-media activity is advertising and must comply with this Manual. Agents must not publish misleading claims, discriminatory content, confidential information, unauthorized media, undisclosed paid endorsements, false reviews, altered property images that misrepresent condition, or personal opinions presented as official PBRC positions.

10. Listings and Seller Representation

Before marketing a property, the Brokerage must possess an effective listing agreement or other lawful written authorization. Agents must verify material listing information, obtain required disclosures, document marketing and media authorization, follow MLS deadlines, and immediately report title issues, disputes, unusual terms, legal threats, or significant risk.

No listing, coming-soon advertisement, sign, photograph, video, or public promotion may be published without the required authorization.

11. Buyer Representation

Agents must provide required agency disclosures, use Brokerage-approved buyer agreements where required, disclose known material facts, present offers promptly and objectively, protect confidential information, avoid undisclosed conflicts, and comply with all policies concerning showings, compensation, concessions, and written agreements.

12. Transaction Management

Every file must contain all applicable contracts, addenda, disclosures, agency documents, compensation agreements, escrow records, inspection-related documents, association or condominium documents, notices, closing statements, correspondence, and Brokerage compliance forms.

Documents must be submitted within the deadlines established by law, MLS rules, contract, or Broker directive. An incomplete or noncompliant file may delay commission processing to the extent permitted by law and the applicable compensation agreement.

13. Escrow

Agents must immediately deliver entrusted funds to the Broker or authorized escrow holder and promptly report deposits, missed deadlines, returned funds, conflicting demands, disputes, suspected fraud, or other escrow concerns. Agents may not retain or disburse transaction funds except as expressly permitted by law and authorized by the Broker.

14. Fair Housing and Equal Professional Service

Discrimination, steering, discriminatory advertising, discriminatory screening, retaliation, harassment, and unequal service are prohibited. Agents must comply with all protected-class requirements imposed by federal, state, county, and local law. Violations may result in immediate termination and regulatory reporting.

15. Confidentiality, Privacy, and Data Protection

Agents must protect client finances, identification records, negotiations, transaction records, access instructions, alarm and gate codes, lockbox data, passwords, Brokerage records, lead data, and proprietary systems. Information may be accessed and disclosed only for authorized business purposes.

16. Communications

Communications must be professional, accurate, timely, and preserved when relevant to compliance or dispute protection. Agents must immediately notify the Broker of complaints, threats, demands, subpoenas, attorney communications, fair-housing concerns, media inquiries, data breaches, suspected fraud, and circumstances reasonably likely to expose PBRC to liability.

17. Office Conduct

Harassment, discrimination, intimidation, violence, threats, retaliation, theft, misuse of Brokerage property, disruption, and unprofessional conduct are prohibited. Agents must respect staff, agents, clients, vendors, cooperating parties, and the public.

18. Ethics and Professional Conduct

Agents must avoid dishonest conduct, misrepresentation, concealment, conflicts of interest, improper inducements, fee manipulation, anticompetitive conduct, and interference with another licensee's lawful relationship. Applicable REALTOR(R) ethical duties must also be followed.

19. Broker Approval and Supervision

The Broker may review, approve, reject, remove, correct, or require revision of advertisements, transaction documents, contract language, public communications, business practices, and technology uses involving PBRC. Agents must provide requested information and cooperate with supervision, audits, investigations, legal review, and corrective measures.

20. Violations and Corrective Action

Depending on severity, corrective action may include education, written warning, required correction, removal of advertising, restriction of systems or marketing privileges, reassignment of leads, reimbursement obligations, suspension, termination, reporting to authorities, and other lawful remedies. Serious conduct may result in immediate termination.

21. Manual Updates

PBRC may amend this Manual prospectively. Updated versions may be distributed electronically or posted in an agent portal or other designated location. Agents are responsible for reviewing notices and updates. A separate signed acknowledgment will be obtained whenever legally required or deemed appropriate by the Broker.

22. Final Compliance Acknowledgment

Continued affiliation indicates acknowledgment of the Brokerage's operating policies to the fullest extent permitted by law. It does not replace a separate signature where law or an applicable agreement requires one. Failure to comply may result in corrective action, termination, reimbursement, indemnification, or other lawful remedies.

23. Commission Policy and Commission Protection

Commission compensation is governed by Florida law, the applicable Independent Contractor Agreement, written compensation schedules, transaction-specific agreements, and this Manual.

Unless a written agreement provides otherwise, no agent compensation is payable until:

• The transaction has closed and funded or the Brokerage has otherwise become legally entitled to retain the commission;
• The Brokerage has actually received the applicable commission in cleared funds;
• The agent has submitted a complete and compliant file;
• Required disbursement authorization has been obtained; and
• Lawful deductions, offsets, referral obligations, chargebacks, or other amounts authorized by a signed agreement have been calculated.

PBRC may deduct or offset only amounts permitted by law and an applicable written agreement. This Manual does not authorize forfeiture of earned wages or compensation contrary to law.

24. Company Leads and Mandatory 50% Commission Split

Ownership and Definition of Company Leads

All leads generated, received, purchased, created, assigned, or produced through PBRC's name, reputation, listings, offices, personnel, telephone numbers, websites, domains, advertising, technology, databases, social-media accounts, signs, marketing expenditures, or other Brokerage resources are "Company Leads" and remain Brokerage business opportunities.

Company Leads include, without limitation:

• All calls, text messages, voicemails, or other inquiries made to a company-owned or company-advertised telephone number;
• All walk-ins or visitors to a PBRC office;
• All website, portal, registration, chat, contact-form, email, social-media, and digital-advertising inquiries received through a Brokerage-controlled source;
• Leads produced by company-paid advertising, signs, mailers, events, campaigns, databases, or marketing systems;
• Leads assigned by the Broker, staff, lead coordinator, or another authorized representative;
• Inquiries arising from any PBRC listing, including calls, messages, open-house contacts, showing requests, property tours, previews, or other contacts concerning a company listing;
• Any buyer, seller, landlord, tenant, investor, or referral relationship first created through a Company Lead; and
• A client originating from a Company Lead who later purchases, sells, rents, leases, or lists a different property.

Required Split

Unless the Broker approves a different split in a separate writing, every closed sale, purchase, lease, rental, referral, or other compensated transaction arising from a Company Lead shall be paid on a mandatory fifty-percent (50%) split to PBRC and fifty-percent (50%) split to the servicing agent.

The split is calculated from the gross brokerage commission actually received by PBRC for the side of the transaction serviced by the agent, after deducting any outside referral fee, court-ordered payment, client rebate, commission credit, or other third-party amount that PBRC was obligated in writing to pay from that commission. Brokerage transaction fees, technology fees, E&O charges, advances, chargebacks, and other agent obligations may then be applied only as authorized by the applicable Independent Contractor Agreement or other signed compensation agreement.

Continuing Classification

A Company Lead does not become a personal lead merely because the agent develops the relationship, shows properties, changes the property being considered, changes the transaction type, or communicates through a personal telephone number, email address, CRM, or social-media account. The 50% Company Lead split applies to transactions completed during the agent's affiliation that arise from the original Company Lead unless the Broker reclassifies the lead in writing.

Showing and Listing Leads

A person who contacts PBRC about a company listing, attends a showing or open house of a company listing, or is introduced to an agent through activity involving a company listing is a Company Lead. The 50% split applies even when the person ultimately purchases, leases, sells, or lists a property other than the property that generated the initial inquiry or showing.

Lead Records and Attribution

Agents must promptly enter Company Leads into the designated Brokerage system and accurately preserve the lead source, communications, appointments, showings, and transaction history. Concealing, deleting, changing, diverting, transferring, or falsely describing a Company Lead is prohibited.

The Broker will determine lead attribution in good faith based on available records, lead-source data, communications, showing records, and transaction history. Any contractual right to challenge the determination is governed by the applicable Independent Contractor Agreement and dispute-resolution provision.

Prohibited Diversion

An agent may not divert a Company Lead to another brokerage, unlicensed person, affiliated business, outside team, personal entity, family member, or third party; conceal a resulting transaction; delay a transaction to avoid a split; or arrange payment outside PBRC. Such conduct constitutes a material breach and may result in termination, recovery of unpaid compensation, reimbursement of losses, attorneys' fees where authorized, regulatory reporting, and other lawful remedies.

Survival and Separate Agreement

Lead-source records, payment obligations on transactions initiated during affiliation, confidentiality duties, reimbursement obligations, and accrued rights survive termination. Any post-termination commission, referral, or restrictive obligation shall be governed by the applicable signed Independent Contractor Agreement or other enforceable written agreement.

25. Dispute Resolution, Mediation, and Arbitration

Disputes must first be submitted to the Broker for internal review. Any mandatory mediation or binding arbitration obligation must be contained in an applicable signed or validly electronically accepted agreement that identifies the scope, governing rules, venue, allocation of costs, and available remedies. Nothing in this Manual alone should be interpreted to waive a right to court adjudication where a valid arbitration agreement has not been formed.

26. Nonsolicitation and Protection of Brokerage Relationships

Agents may not misuse confidential Brokerage data, trade secrets, nonpublic lead records, transaction records, passwords, proprietary systems, or other protected information.

Any post-termination nonsolicitation or restrictive covenant, including a proposed twelve-month restriction, is enforceable only to the extent stated in a separate written agreement signed by the person against whom enforcement is sought and supported by a legitimate business interest and reasonable scope under applicable Florida law. This Manual alone does not create a post-termination restrictive covenant.

27. Artificial Intelligence and Technology Use

Agents remain fully responsible for all AI-assisted work. AI may not be used to create false listing information, fabricated property features, discriminatory content, misleading images, unauthorized derivative works, legal advice, or unverified contract language. All AI output must be reviewed for accuracy, authority, confidentiality, Fair Housing compliance, copyright compliance, and lawful use before publication or delivery.

28. Wire-Fraud Prevention

Agents must warn clients in writing about wire fraud, direct clients to verify wiring instructions with the title or closing agent using independently verified contact information, never independently alter or approve wiring instructions, and immediately report suspicious messages or payment changes. Email alone is insufficient verification.

29. Open Houses, Showings, and Property Access

Agents must follow safety procedures, showing instructions, lockbox rules, occupancy restrictions, seller instructions, and access limitations. Keys, codes, and access credentials may not be shared with unauthorized persons. Agents are responsible for damage, loss, injury, or security incidents caused by their negligence, misconduct, or violation of instructions, to the fullest extent permitted by law.

30. Technology, MLS Access, and Cybersecurity

Agents must secure MLS accounts, lockbox access, email, CRM, transaction systems, passwords, devices, and confidential information. Sharing credentials, permitting unauthorized access, storing confidential information insecurely, or allowing unlicensed persons to perform licensed activity is prohibited. Suspected phishing, compromise, or data breach must be reported immediately.

31. MLS Fines, Regulatory Penalties, and Financial Responsibility

Agents are responsible, to the fullest extent permitted by law and applicable signed agreements, for MLS fines, association penalties, lockbox charges, advertising penalties, copyright claims, municipal violations, Fair Housing violations, chargebacks, and other losses caused by their acts or omissions. Reimbursement obligations survive termination.

32. Electronic Records and Signatures

Electronic signatures, electronic acknowledgments, and electronic records may be used when the parties have agreed to conduct the transaction electronically and applicable law recognizes the method used. PBRC may require authentication, proof of delivery, an audit trail, or a separate signed agreement. Mere website availability or silence does not substitute for a signature when a signed writing is legally required.

33. Broker's Final Operational Authority

The Broker retains final operational and supervisory authority over PBRC's transactions, advertising, systems, compliance, lead assignment, policy interpretation, file approval, risk management, and commission processing, subject to applicable law and binding written agreements. Nothing in this section permits arbitrary withholding of legally earned compensation or overrides nonwaivable legal rights.

34. Final Brokerage Protection Statement

Affiliation with PBRC is conditioned upon lawful, ethical, and professional conduct. Compliance, client protection, public protection, accurate records, risk management, and protection of the Brokerage's legitimate business interests take priority over personal convenience or unauthorized practices.

Strict compliance is mandatory.

End of Pompano Beach Realty Corporation Policy & Procedures Manual