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Compliance Policy

  • Effective Date: April 2025
  • Owner: Operations Team
  • Approved By: Senior Management Team

The purpose of this policy is to ensure that Code Town identifies, monitors, and complies with all applicable legal, regulatory, and contractual obligations. This policy establishes a structured framework for maintaining compliance and assigning responsibilities across the organization.

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.

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
  • Taking timely action to address non-compliance or potential risks

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
RoleResponsibilities
Senior ManagementProvide leadership and resources for compliance; review and approve policies; promote a culture of compliance
Compliance Officer/TeamMaintain the Compliance Register, monitor changes in law, assess risks, support audits, and provide training
Department HeadsImplement compliance procedures in their areas; report non-compliance issues
Employees and ContractorsFollow policies and procedures; report potential violations; complete required compliance training
Vendors/Third PartiesAdhere to contractual and legal obligations; undergo periodic assessments if required

Compliance will be monitored through:

  • Internal and external audits
  • Ongoing legal and regulatory monitoring
  • Incident and breach reporting mechanisms
  • Periodic policy and register reviews (at least annually or as required)

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.

All relevant personnel shall receive compliance training appropriate to their roles. Refresher training will be conducted periodically or when significant changes in obligations occur.