This policy outlines the process for the Compliance Officer to engage other company departments in drafting or revising policies and guidelines, recognizing the Compliance Department's resource constraints. The Compliance Department has the authority to request new or revised policies, circulate drafts for feedback, and work with other departments to finalize these documents. The decision to create a new policy or revise an existing one rests with the Compliance Department, which may use a two-step analysis to make this determination