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Business Continuity Plan

DISCLOSURE STATEMENT OF BUSINESS CONTINUITY PLAN

Austin Atlantic has developed a Business Continuity Plan describing how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, our plan is structured to be flexible in responding to actual events as they occur. With that in mind, we are providing you this information on our Business Continuity Plan.

Our firm’s policy is to respond to a Significant Business Disruption by safeguarding employees’ lives and firm’s property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records. In the event that we determine we are unable to continue our business (Austin Atlantic does not anticipate such drastic results), shareholders have access to their accounts held at the funds administrator and transfer agent, Northern Trust Bank. Austin Atlantic does not hold shareholder accounts. The firm, in case of a Significant Business Disruption, expects to resume business and operations within hours. Off-site locations have been designated by our firm to resume operations promptly and avoid any down time in business and operations. Our Business Continuity Plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Fund Shareholders should contact Northern Trust Bank Shareholder Services at 800-247-9780.

Austin Atlantic, when practicable and reasonable, will update its website, www.austinatlantic.com, with any updates relating to our business interruption. Shareholders are welcome to contact Austin Atlantic; however, all fund account information is with Northern Trust. Accounts advised by Austin Atlantic, non-fund related, are held at your custodian.

Our goal is to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records. Please note that shareholders transact business via Northern Trust.

Our Business Continuity Plan addresses: data backup and recovery; all mission critical systems financial and operational assessments; alternative communications with shareholders, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting.

Northern Trust, backs up our important records in a geographically separate location and server/cloud systems. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by Northern that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within hours. Your orders and requests for funds and securities could be delayed during this period.

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to another firm location or local site when needed and expect to recover and resume within hours or the same day. In a disruption affecting our business district, city or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within hours or the same day. In either situation, we plan to continue in business notify you through our website www.austinatlantic.com or a customer emergency number to be posted on our website. If the significant business disruption is so severe that it prevents us from remaining in business, we will post this information to our website.

For more information regarding our Business Continuity Plan, you can contact us at 305-507-1536 or krowe@austinatlantic.com. A complete version of Austin Atlantic, Inc. Business Continuity Plan is available upon request.

 

Austin Atlantic’s Office Location and Phone number:

1 Alhambra Plaza, Suite 100, Coral Gables, FL 33134,

305-379-6656