Compliance Standards and Procedures

Model Policy Management Policy

Function

Effective Date

Pages

Revision Date

Global Compliance

[Effective Date]

3

[Revision Date]

Scope: This Compliance Management Policy applies to the creation, approval, adoption, and maintenance of all compliance policies along with all related procedures (together, the “compliance policies and procedures”) of [INSERT COMPANY NAME] (the “Company”).

Purpose: Company compliance policies and procedures are designed to ensure compliance with our Code of Conduct and with applicable laws. Our compliance policies and procedures are managed by the Company’s Global Compliance Committee (GCC). Only the GCC has the authority to issue or revise the Company’s compliance policies and procedures. This policy is intended to ensure we have a uniform process for the creation, approval, adoption, and maintenance of such policies.

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