Podesta & Co

I. Emergency Contact Persons II. Firm Policy III. Business Description IV. Office Location V. Alternative Physical Location(s) of Employees VI. Customers’ Access to Funds and Securities VII. Data Back-Up and Recovery (Hard Copy and Electronic VIII. Financial and Operational Assessments IX. Mission Critical Systems X. Alternate Communications Between the Firm and Customers, Employees and Regulators XI. Critical Business Constituents, Banks, and Counter-Parties XII. Regulatory Reporting XIII. Disclosure of Business Continuity Plan XIV. Updates and Annual Review XV. Senior Manager Approval

II. Firm Policy

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.

A. Significant Business Disruptions (SBDs)

Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

B. Approval and Execution Authority

Victor Elting III, a registered principal, is responsible for approving the plan and for conducting the required annual review. Carol Podesta Foley, CEO has the authority to execute this BCP.

C. Plan Location and Access

Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on the front office computer in Microsoft Word, My Documents, Victor, and Business Continuity Plan Template. Also, a copy is included in our Written Supervisory Procedures.