Steadworth Vendor
Management Policy

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") relies on vendors and service providers ("Vendors") to support its business operations, including its Home Wealth Share Program ("Program"). This Vendor Management Policy ("Policy") establishes a framework for managing Vendor relationships and mitigating the risks associated with such relationships.

II. Policy Statement

Steadworth is committed to managing Vendor relationships in a prudent and responsible manner. This includes conducting appropriate due diligence, monitoring Vendor performance, and ensuring that Vendors comply with all applicable laws and regulations.

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents involved in the selection, engagement, and management of Vendors.

IV. Vendor Management Program

Steadworth will implement a Vendor Management Program that includes the following elements:

A. Risk Assessment:

• Identifying and assessing the risks associated with each Vendor relationship.
  
  

B. Due Diligence:

• Conducting due diligence on potential Vendors before entering into a contract.

• This includes reviewing the Vendor's financial condition, reputation, and compliance with applicable laws and regulations.
  
  

C. Contract Negotiation:

• Negotiating and executing written contracts with all Vendors.

• These contracts will clearly define the scope of services, performance expectations, and compliance requirements.
  
  

D. Ongoing Monitoring:

• Monitoring Vendor performance on an ongoing basis to ensure compliance with the contract and applicable laws and regulations.
  
  

E. Termination and Corrective Action:

• Establishing procedures for terminating Vendor relationships and taking corrective action when necessary.
  
  

V. Responsibilities

A. Compliance Officer:

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

B. Vendor Relationship Manager:

• The Vendor Relationship Manager is responsible for managing the day-to-day relationship with Vendors.
  
  

C. All Employees:

• All employees are responsible for complying with this Policy and reporting any potential Vendor-related issues to the Compliance Officer or Vendor Relationship Manager.
  
  

VI. Training

Steadworth will provide training to employees on this Policy and the Vendor Management Program.

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 managing Vendor relationships in a prudent and responsible manner. This Policy is intended to ensure that all Vendor relationships are managed in accordance with applicable laws and regulations and that the risks associated with such relationships are mitigated.

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.