Business Continuity Plan

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

Our plan considers a number of scenarios including disruption to a single building, or a city-wide or regional business disruption. Many of our functions and systems are dependent upon the companies we do business with. The companies have indicated that in the event of a significant business disruption, it may relocate technology and operational personnel to pre-assigned alternate regional facilities and switch technology data processing to an alternate regional data center. Their redundant data centers and alternate processing facilities will help minimize interruptions to our services.

Contacting Us — If after a significant business disruption you cannot contact us as you usually do at (212) 970-3700, you should call our cellular phone numbers which are listed on our business cards.

Our Business Continuity Plan — We plan 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, and allowing our customers to transact business. In short, 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.

Our business continuity plan addresses — Data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact and regulatory reporting if we are unable to continue our business. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption; our objective is to restore our operations and be able to complete existing transactions and accept new transactions within a reasonable time period.

Varying Disruptions — Significant business disruptions can vary in their scope, such as only our firm, a single building or unit 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 a local site when needed and expect to recover and resume business within a few hours. 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 a day. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our phone system or our customer emergency number, how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and financing.

For more information — If you have questions about our business continuity planning or would like a copy of the complete Business Continuity Plan for E.F. Hutton & Co., please contact us directly at (212) 970-3700.