1031 Marketing provides Beer, Wine and Spirits suppliers 3rd Party Billing services within the guidelines, regulations, and statutes throughout the United States.

1031 Marketing 3rd Party Billing Programs

1031 Marketing offers Scan and Digital Coupon Redemption services to adult beverage industry suppliers and retailers. As your 3rd Party Billing provider we will:

• Receive and verify retailer's invoice for all program redemption costs

• Invoice alcohol beverage supplier for all program redemption costs and provide retailer documentation with proof of sale

• Receive payment from supplier and pay retailer

1031 Marketing 3rd Party Billing Agreement

The scan back, digital coupon, member loyalty or register savings programs (“3rd Party Billing Programs”) during the stated time period are available to customers in certain states over the age of 21 who purchase the agreed upon product(s) during the promotional period from participation retail locations. The 3rd Party Billing Programs will provide eligible customers (defined as Legal Drinking Age in the participating state) with instant savings in the amount stated on retailer point of sale at participating retail locations during select promotional periods which are only determined by the supplier and participating retailer(s).  Each participating retailer will be reimbursed for the offers redeemed during the promotional period, plus reimbursement of any transaction fees.  The retailer is responsible for providing an accurate accounting of the amount of program offers which have been redeemed. 1031 Marketing requires the following information from participating retailers within 30 days of the conclusion of the 3rd Party Billing Program:

• Total Number of Units sold during the promotional period with back-up/proof of performance

• An invoice showing the total dollar amounts per program and a grand total that you are expecting. Include an invoice number or a payment reference for 1031 Marketing to put on your check.

The above information should be submitted to 1031 Marketing by email to dave.1031marketing@gmail.com. 1031 Marketing Incorporated is not responsible for verifying that the number of program offers which have been redeemed is correct.

1031 Marketing will not reimburse a retailer unless and until it is paid by the participating supplier.  In the event that the supplier does not pay 1031 Marketing for any reason, 1031 Marketing will not be responsible for reimbursing the retailer.

DISCLAIMER: VOID WHERE PROHIBITED BY LAW. 1031 Marketing has no ownership interest in any retailer, wholesaler, or manufacturer of alcoholic beverages. 1031 Marketing reserves the right to withdraw, without penalty, from any activity which we deem to be noncompliant with any regulatory agency, in any jurisdiction, where our services are being provided.

1031 Marketing 3rd Party Alcohol Promotion Compliance Policy

1.1 Purpose and Policy Statement

1031 Marketing is committed to conducting consumer alcohol promotions and related marketing services transparently, accurately and in compliance with applicable federal, state and local law. 1031 will not knowingly facilitate an improper payment, undisclosed personal benefit, false or misleading invoice, concealed beneficiary, off-book incentive, or circumvention of a client's compliance controls.

Core operating rule: the authorization, business purpose, source of funds, invoice, recipient or beneficiary, payment, fulfillment evidence and final reconciliation must tell the same truthful story.

1.2 Scope

This policy applies to all 1031 Marketing owners, officers, employees, contractors and agents involved in alcohol-industry promotions, including consumer rebates, sweepstakes, contests, gift cards, prizes, promotional merchandise, event support, supplier billbacks, distributor or retailer-related programs, travel/entertainment support, reimbursements, vendor payments and promotional fund administration.

1.3 Roles and Responsibilities

• Employees/request processors: collect required documentation, perform the Employee Transaction Checklist, accurately code the beneficiary and stop questionable transactions.

• Managers: verify business purpose, commercial reasonableness, approval authority and completeness of documentation; never pressure employees to override a compliance hold.

• Compliance designee: review yellow/red-flag transactions, maintain the escalation log, coordinate legal review, training, monitoring and periodic risk assessments.

• Finance/accounts payable/receivable: pay only approved vendors and approved transactions; reject unsupported, duplicate, split, vague, altered or inconsistent invoices.

• Executive management: support independent compliance decisions, provide adequate resources and ensure no retaliation for good-faith reporting.

1.4 Required Promotion File

Each material promotion or transaction must have a unique Promotion/Transaction ID. The file should contain, as applicable: client authorization; program description and terms; brand and market; funding source; requester and approver; recipient/beneficiary classification; vendor information; quotes/POs; invoices and receipts; gift-card or prize controls; event attendee/agenda information; proof of consumer fulfillment; billback support; payment evidence; exceptions/approvals; final reconciliation; and disposition/refund of unused funds.

1.5 Accurate Invoicing and Books-and-Records Standard

1031 will create, approve and process only records that accurately describe the underlying transaction. No employee may falsify, backdate, omit a material beneficiary, use a misleading description, create a fictitious event or service, disguise gift cards or personal benefits as another expense, or alter documentation to obtain approval.

Prohibited examples include: describing gift cards as generic marketing services; omitting a retailer employee from an event invoice when that person's costs are being funded; creating a billback for an event that did not occur; splitting an expense to remain below an approval threshold; or routing a payment through another vendor or supplier to avoid a client's controls.

1.6 Gift Cards, Cash Equivalents and Prizes

Gift cards and cash equivalents are high-risk and require enhanced controls. The file must identify the program, funding source, requester, quantity, denomination, total value, intended recipient category, actual distribution or fulfillment evidence, unused balance and reconciliation. Gift cards must not be converted into an informal personal account, “bank,” travel fund or stored benefit for an employee of a supplier, distributor or retailer.

Consumer rewards may be processed only under a documented consumer program and subject to applicable legal requirements. Any proposed benefit to a retailer employee/buyer, distributor employee, supplier employee, government official or other individual whose business decisions may be influenced must be placed on compliance hold pending written approval from Compliance and, where appropriate, beverage-alcohol counsel.

1.7 Travel, Entertainment, Events and Things of Value

Travel, lodging, golf, tickets, meals, spa services, luxury goods, casino-related expenditures and similar things of value require enhanced review. Documentation must identify the legitimate business purpose, attendees, payer/funding source, itinerary or agenda where appropriate, itemized costs and the relationship of each expense to the approved program. Personal substitutions, cash-outs or credits for unused travel are prohibited unless specifically approved in writing after legal review.

1.8 Retailer, Distributor and Supplier Employees

1031 must distinguish the business entity from its employees. A payment to a retailer is not the same as a personal benefit to a retailer buyer. The same distinction applies to supplier and distributor personnel. Employees must code the ultimate beneficiary and may not rely solely on the identity of the invoiced company. Any personal benefit connected to purchasing, placement, promotion, maintenance or sale of alcohol products is a red flag requiring escalation.

1.9 Vendors and Subcontractors

Before use, material third-party vendors should be risk-rated and approved. Due diligence should consider ownership, relationships with clients or alcohol-industry employees, services, qualifications, reputation, conflicts, payment instructions and any unusual compensation. Contracts should require legal compliance, accurate records, cooperation with audits/investigations, preservation of records, and the right to suspend or terminate for compliance concerns.

1031 should periodically review higher-risk vendors and should not pay an unapproved vendor merely because a client employee requests it. Changes in ownership, bank account, scope, payment destination or beneficiary may trigger re-review.

1.10 Transaction Approval and Escalation

Routine low-risk transactions may proceed after completion of required controls. Yellow-flag transactions require documented manager or Compliance review. Red-flag transactions must be placed on hold and submitted on the Red-Flag Escalation Form. No employee may override a compliance hold. Only the designated Compliance authority, with legal advice where appropriate, may release a held transaction.

1.11 Reporting, Non-Retaliation and Investigations

Employees must promptly report suspected violations, inaccurate records, hidden beneficiaries, pressure to circumvent controls, or other red flags. Good-faith reporting is protected from retaliation. Compliance will document the allegation, preserve relevant records, assess whether counsel should direct the investigation, determine remediation, and maintain an investigation/exception log.

1.12 Record Retention

1031 will retain promotion, invoice, approval, fulfillment, reconciliation and compliance records for the period required by applicable law, contract and any litigation/legal hold. Records relevant to an investigation, audit, subpoena, government request or legal hold must not be deleted or altered. Business communications concerning material approvals should be preserved in approved company systems.

1.13 Training, Certification and Monitoring

Relevant personnel should receive training at onboarding and periodically thereafter on this policy, alcohol trade-practice risk, accurate invoicing, gift cards, third parties and escalation. 1031 should conduct periodic risk-based testing of promotion files, invoices, billbacks, gift-card reconciliations and vendor payments. Higher-risk transactions and vendors should receive greater sampling.

1.14 Discipline and Remediation

Violations may result in corrective action up to and including termination of employment or vendor relationship. Remediation may include transaction reversal, refund, corrected records, enhanced controls, retraining, vendor suspension, internal investigation, client notification and consultation with counsel regarding any reporting obligation.

About

1031 Marketing Inc. is a leading 3rd Party Billing company serving the adult beverage industry. Founded in 2014 by Dave Olsen, a beer industry veteran, 1031 has worked with hundreds of suppliers and retailers across multiple states. We pride ourselves on making sure retailer payments are handled in a timely manner.

“I ran scan programs when I was working as a beer supplier starting back in the early 90’s. After being frustrated with poor service and excessive fees, I knew there had to be a better solution so I started 1031 to make sure suppliers and retailers have a fast, professional and reliable 3rd Party to help them manage their promotions.” Dave