Steadworth Record Management and Retention Policy

I. Introduction

Steadworth, LLC ("Steadworth") is required by applicable laws and regulations to maintain certain corporate records for specific periods of time and in a secure and accessible manner. This Record Management and Retention Policy ("Policy") establishes a framework for the identification, preservation, and disposal of Steadworth's corporate records.

II. Purpose

The purpose of this Policy is to:

• Ensure compliance with all applicable record retention rules.

• Protect the integrity and availability of corporate records.

• Mitigate legal and regulatory risks associated with improper record retention.
  
  

III. Scope

This Policy applies to all corporate records created, received, or maintained by Steadworth, regardless of format (e.g., paper, electronic). This includes, but is not limited to:

• Business records (e.g., financial records, employee information, customer correspondence).

• Legal records (e.g., litigation records, contracts).

• Personal records (e.g., employee emails).
  
  

IV. Record Location and Format

Corporate records will be stored in a secure and accessible location, in a format that complies with applicable record retention rules. Electronic records will be maintained in a manner that ensures their authenticity, integrity, and accessibility.

V. Record Disposition

Steadworth will establish procedures for the secure and compliant disposal of corporate records when their retention period has expired.

VI. Legal Hold Requirements

Steadworth may suspend the disposal of corporate records subject to a legal hold. A legal hold will be implemented when Steadworth is involved in litigation, is subject to a government investigation, or when there is a reasonable anticipation of litigation or investigation.

VII. Vendor Relationships

Steadworth will ensure that any vendors who maintain corporate records on its behalf comply with this Policy and applicable record retention rules.

VIII. Training

Steadworth will provide training to employees on their responsibilities under this Policy.

IX. Responsibilities

A. Compliance Officer:

• The Compliance Officer is responsible for overseeing and implementing this Policy.

B. All Employees:

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

X. Review and Revision

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

XI. Conclusion

Steadworth is committed to maintaining a comprehensive and compliant record management and retention program. This Policy is intended to ensure that all corporate records are managed and retained in accordance with applicable laws and regulations.

XII. 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.