Steadworth Unfair, Deceptive, and Abusive Acts or Practices (UDAAP) Policy

Effective Date: Not Effective Currently

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to treating consumers fairly and ethically in all aspects of its business, including its Home Wealth Share Program ("Program"). This Unfair, Deceptive, and Abusive Acts or Practices (UDAAP) Policy ("Policy") outlines Steadworth's commitment to avoiding UDAAPs and promoting a culture of consumer protection.

II. Policy Statement

Steadworth will not engage in any acts or practices that are unfair, deceptive, or abusive to consumers. This includes, but is not limited to, the following:

Unfair Acts or Practices: Steadworth will not engage in any practices that cause or are likely to cause substantial injury to consumers that cannot be reasonably avoided or that are not outweighed by countervailing benefits to consumers or competition.
Deceptive Acts or Practices: Steadworth will not make any representations or omissions that are likely to mislead consumers acting reasonably under the circumstances. All material information about the Program will be disclosed clearly and conspicuously.
Abusive Acts or Practices: Steadworth will not engage in any practices that take unreasonable advantage of consumers or interfere with their ability to understand the terms and conditions of the Program.

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents involved in any aspect of the Program.

IV. Responsibilities

A. Compliance Officer:

The Compliance Officer is responsible for overseeing and implementing this Policy.
This includes developing and maintaining procedures, providing training to employees, and monitoring compliance with this Policy.

B. All Employees:

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

V. UDAAP Risk Management

Steadworth will implement a process for identifying and assessing UDAAP risks associated with the Program. This process will include:

Conducting regular risk assessments.
Reviewing consumer complaints.
Monitoring marketing and advertising materials.
Reviewing and updating policies and procedures.

VI. Training

Steadworth will provide regular training to its employees on UDAAP compliance. This training will cover topics such as the UDAAP standards, how to identify and report potential UDAAP violations, and best practices for avoiding UDAAPs.

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 avoiding UDAAPs and promoting a culture of consumer protection. This Policy is intended to ensure that all employees are aware of their obligations under this Policy and that Steadworth conducts its business in a compliant and ethical manner.

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.