Steadworth Compliance
Management System Policy

1. Introduction

Steadworth, LLC ("Steadworth", "we", "us", or "our") is committed to conducting its business in compliance with all applicable laws and regulations. This Compliance Management System Policy ("Policy") establishes a framework for our compliance management system ("CMS") to ensure that we meet this commitment.

2. Purpose

The purpose of this Policy is to:

• Define the scope and objectives of our CMS.

• Assign responsibility for developing, implementing, and maintaining our CMS.

• Establish a process for identifying and assessing compliance risks.

• Develop and implement controls to mitigate compliance risks.

• Monitor and review the effectiveness of our CMS.
  
  

3. Scope and Objectives

Our CMS is designed to ensure compliance with all applicable laws and regulations, including but not limited to:

• Consumer protection laws

• Fair lending laws

• Data privacy and security laws
  
  

The objectives of our CMS are to:

• Prevent and detect violations of applicable laws and regulations.

• Promote a culture of compliance within Steadworth.

• Protect the interests of our customers and stakeholders.
  
  

4. Responsibility

The Compliance Officer is responsible for developing, implementing, and maintaining our CMS. The Compliance Officer will also be responsible for overseeing the compliance activities of all Steadworth employees.

5. Compliance Risk Management

We will implement a process for identifying and assessing compliance risks. This process will include:

• Conducting a risk assessment to identify potential compliance risks.

• Evaluating the likelihood and impact of each identified risk.

• Developing and implementing controls to mitigate compliance risks.
  
  

6. Compliance Controls

We will develop and implement appropriate controls to mitigate compliance risks. These controls may include:

• Policies and procedures

• Training programs

• Monitoring and auditing activities
  
  

7. Monitoring and Review

We will monitor and review the effectiveness of our CMS on a regular basis. This will include:

• Conducting compliance audits

• Reviewing compliance reports

• Taking corrective action as needed
  
  

8. Continuous Improvement

We are committed to continuous improvement of our CMS. We will regularly review and update our CMS to ensure that it remains effective and relevant.

9. Effective Date

This Policy is effective as of the date first written above.