Business Continuity Plan
ETF Capital Management (ETFCM) understands that continuity of our operations is critical to the protection of our clients. This document sets out the steps that can be taken to compensate for disruptions that may affect ETFCM's business operations conducted at its Toronto, Ontario headquarters location. The “Plan” sets forth ETFCM's objectives of protecting employees, recovering and resuming operations, protecting records, and enabling communications with employees, clients, key service providers, and regulators. The Plan also covers ETF Capital Research, a wholly owned subsidiary of ETFCM.

The Plan addresses both disruptions that may be caused by an incident within our premises (such as a fire), or by a regional or market-related disruption that applies to many companies. The Plan covers ETFCM's critical business processes and related people that are essential for ETFCM to continue to conduct business for an interim or temporary period during a business interruption. All of the most important aspects of ETFCM's advisory business, including continued investment management, trading, and rapid communication to key business partners and clients, is addressed in these processes. ETFCM's primary business recovery strategy is to resume its critical business processes and/or provide access to key critical systems/applications from remote locations, with minimal interruption as soon as possible, depending on the nature or severity of the disruption.

Disruption at our Headquarters: Fire, power, or other local situations could prevent us from gaining access to, or operating from our building and offices. All of our computer systems are protected from power surges, and vital trading equipment switches seamlessly to backup power units to help mitigate the circumstances. Proprietary information contained on our systems is backed up daily to a geographically distant server and on regular intervals to backup drives housed both inside and outside our Toronto headquarters. If it becomes impractical or impossible to operate from our offices, all our key employees are able to access critical aspects of the ETFCM infrastructure from their designated alternate locations, and our 888-383-9753 customer phone line will be redirected to these alternate locations. Communication by e-mail is available to our workforce from any computer in the world, and remotely on mobile devices and thus we expect it would be unaffected by a scenario where only our headquarters location is affected.

Disruption Affecting the Local Area: More widespread conditions could prevent our staff from reaching our offices. Should this occur, we will follow the alternate location protocols described above. In the event the alternate locations are affected by a power outage or communications disruption, and wherever possible, critical functions will be moved outside of the affected area using our mobile field systems for investment management, trading, and communications. In all cases, the integrity and security of client information will be safeguarded.

ETFCM's Plan identifies measures to be taken to address temporary business disruptions in a organized and methodical way. The very nature of disasters makes their effect unpredictable. There can be no assurance that any plan can address such unforeseen contingencies. Should you have questions regarding an ETFCM account, please contact your financial advisor directly. Institutional Account holders should contact Jared Rabinowitz, President & COO, at 416.223.3837. This plan is subject to adjustment from time to time as determined by ETFCM’s operational requirements.
© ETF Capital Management 2012