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

XV. Senior Manager Approval

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.