Steadworth Compliance Testing and Monitoring Policy

Effective Date: Not Effective Currently

I. Introduction

Steadworth, LLC ("Steadworth") is committed to conducting its business in compliance with all applicable laws and regulations. This Compliance Testing and Monitoring Policy ("Policy") establishes a framework for Steadworth's compliance testing and monitoring program.

II. Purpose

The purpose of this Policy is to:

Ensure that Steadworth's compliance program is effective in preventing and detecting violations of applicable laws and regulations.
Identify and assess compliance risks.
Develop and implement controls to mitigate compliance risks.
Monitor and review the effectiveness of Steadworth's compliance program.

III. Scope

This Policy applies to all of Steadworth's business operations, including its Home Wealth Share Program ("Program").

IV. Compliance Testing and Monitoring Program

Steadworth's Compliance Officer will develop and implement a risk-based compliance testing and monitoring program. This program will include:

Risk Assessment: Identifying and assessing compliance risks associated with Steadworth's business operations.
Compliance Testing: Conducting tests to assess the effectiveness of Steadworth's compliance controls.
Compliance Monitoring: Monitoring Steadworth's business operations for compliance with applicable laws and regulations.

V. Responsibilities

A. Compliance Officer:

The Compliance Officer is responsible for overseeing and implementing the compliance testing and monitoring program.

B. All Employees:

All employees are responsible for complying with this Policy and reporting any potential compliance violations to the Compliance Officer.

VI. Reporting and Corrective Action

The Compliance Officer will report the results of compliance testing and monitoring activities to senior management and the Board of Directors. Any identified compliance deficiencies will be addressed through appropriate corrective action plans.

VII. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

VIII. Conclusion

Steadworth is committed to maintaining a strong compliance program. This Policy is intended to ensure that Steadworth's compliance program is effective in preventing and detecting violations of applicable laws and regulations.

IX. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at: contact@steadworth.com

Please note: This Policy is intended to supplement, not replace, any other applicable Steadworth policies or procedures.