Compliance Policy
Purpose
Section titled “Purpose”The purpose of this policy is to ensure that Code Town systematically identifies, documents, investigates, and addresses all applicable legal, regulatory, contractual, and information security obligations. This policy establishes a structured framework for compliance management, including corrective action procedures that prevent recurrence of non-conformities and drive continuous improvement.
This policy applies to
- All employees, contractors, and temporary staff.
- Third-party vendors and service providers with access to Code Town systems or data.
- All business units and subsidiaries, where applicable.
Policy Statement
Section titled “Policy Statement”Code Town is committed to:
- Identifying all relevant legal, regulatory, and contractual obligations
- Maintaining an up-to-date compliance register
- Monitoring compliance status and changes to applicable requirements
- Assigning clear roles and responsibilities for compliance management
- Conducting root cause analysis for non-conformities
- Implementing corrective and preventive actions to avoid recurrence
- Driving continual improvement of our security and compliance programs
Compliance Register
Section titled “Compliance Register”A centralized Compliance Register shall be maintained and updated regularly. This register will include:
- Relevant data protection and information security laws (e.g., GDPR, HIPAA, etc.)
- Industry-specific regulations
- Contractual obligations with customers, partners, or vendors
- Internal standards and codes of conduct
The Compliance Team shall:
- Conduct periodic reviews to ensure the register is current
- Track and evaluate legal and regulatory updates
- Inform relevant stakeholders of changes that may affect their responsibilities
Roles and Responsibilities
Section titled “Roles and Responsibilities”| Role | Responsibilities |
|---|---|
| Senior Management | Provide leadership and resources for compliance; review and approve policies; promote a culture of compliance |
| Compliance Officer/Team | Maintain the Compliance Register, monitor changes in law, assess risks, support audits, and provide training |
| Department Heads | Implement compliance procedures in their areas; report non-compliance issues |
| Employees and Contractors | Follow policies and procedures; report potential violations; complete required compliance training |
| Vendors/Third Parties | Adhere to contractual and legal obligations; undergo periodic assessments if required |
Non-Conformity Management and Corrective Actions
Section titled “Non-Conformity Management and Corrective Actions”Code Town shall maintain a structured Non-Conformity and Corrective Action Procedure that includes:
- Identification and Reporting
- All employees, contractors, and vendors must promptly report actual or suspected non-conformities using the official Non-Conformity Report Form
- Reports may be submitted to the Compliance Team via designated reporting channels (e.g., secure email, incident reporting portal)
- Documentation
- All non-conformities will be recorded in the Non-Conformity Log, which
includes:
- Description of the issue
- Date of detection
- Reporter’s name and contact information
- Impact assessment
- Relevant regulatory or contractual obligations
- Assigned owner and target resolution date
- All non-conformities will be recorded in the Non-Conformity Log, which
includes:
- Investigation and Root Cause Analysis
- The Compliance Team (with input from relevant stakeholders) will investigate the issue to determine the root cause, contributing factors, and potential risks.
- Corrective and Preventive Actions
- Appropriate corrective actions will be developed to address the root cause
- Preventive measures will be implemented to reduce the likelihood of recurrence
- Each action will have a designated owner and completion deadline.
- Review and Effectiveness Evaluation
- The Compliance Team will review completed actions to ensure they were implemented effectively.
- If actions are found ineffective, further corrective steps will be taken.
- Continual Improvement
- Findings from non-conformities will be reviewed periodically and used to strengthen Code Town’s security and compliance programs.
Monitoring and Review
Section titled “Monitoring and Review”Compliance will be monitored through:
- Internal and external audits
- Ongoing legal, regulatory, and security monitoring
- Incident, breach, and non-conformity reporting mechanisms
- Periodic policy, register, and corrective and preventive actions reviews (at least annually or as required)
Consequences of Non-Compliance
Section titled “Consequences of Non-Compliance”Any violations of this policy may result in:
- Disciplinary action for internal staff (up to and including termination)
- Contract termination or legal action against third parties
All instances of non-compliance must be reported promptly to the Compliance Team for investigation and remediation.
Training and Awareness
Section titled “Training and Awareness”All relevant personnel shall receive compliance training appropriate to their roles. Refresher training will be conducted periodically or when significant changes in obligations occur.
Appendix
Section titled “Appendix”Non-Conformity Report Form
Section titled “Non-Conformity Report Form”The Code Town approved Non-Conformity Report Form can be found in our Shared Google Drive. To use this form, create a copy of this document, fill out all relevant sections to the best of your abilities and submit it to the Compliance Team within 24 hours of identifying a non-conformity.