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ÃÛѨÊÓƵ is committed to providing highly reliable service and support to our client community. We support this commitment through a comprehensive Business Continuity Program that enables us to respond to and recover from events that could significantly disrupt our business. Our mission is to resume normal business and client support operations with minimal service impact on our clients, in the shortest time possible. Since the timing and impact of disasters and disruptions are unpredictable, we must be flexible in responding to events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

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PROGRAM FRAMEWORK, STRUCTURE AND TOOLS

The Business Continuity Program includes:

Crisis management structure and processÌýto enable immediate response to a disruption at any one of ÃÛѨÊÓƵ’ office buildings or data center facilities, such as a power failure or loss of telecommunications.

Business continuity plansÌýoutline the procedures to be implemented in order to resume critical business activities, including client service and support.

Technical disaster recovery proceduresÌýdetail the steps to be implemented to successfully transition our services from the primary production facility to the designated out of region facility.

In addition, a third-party automated notification service is used to contact key personnel during an event, quickly disseminate critical information, and confirm the safety of our employees.

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OUR BUSINESS CONTINUITY PLAN

ÃÛѨÊÓƵ maintains business continuity plans (BCPs) for all critical services. The business continuity planning process includes the recovery, resumption, and maintenance of all aspects of the business, not just recovery of the technology components. We plan to quickly recover and resume business operations after a significant business disruption by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our clients to transact business.

Our business continuity plan addresses data backup and recovery; all mission critical systems; alternative communications with clients, employees and regulators; alternate physical location of employees; critical third-party dependencies; executive succession plans; and regulatory reporting – all while assuring that our clients have prompt access to their funds and securities if we are unable to operate our business.

BCPs are regularly tested, updated based on changes to business processes, and reviewed as part of an annual review process. Full disaster recovery exercises are run at least annually, with partial testing performed throughout the year to ensure failover capabilities will work when needed.

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COMMUNICATION

Leading up to and during potentially disruptive event, we will keep you updated through our web sites or our customer telephone number.