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Business Continuity Plan (BCP) Disclosure Statement

RESUMPTION OF BUSINESS OPERATIONS FOLLOWING BUSINESS DISRUPTION

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

Action Plan: Via Global Advisors, LLC plans to quickly recover and resume business operations after a significant business disruption (SBD) 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 company’s BusinessContinuity Plan (BCP) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD.

The BCP 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; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Significant Business Disruptions: Via Global Advisors, LLC’s plan takes into account two kinds of significant business disruptions, internal and external. 1. Internal SBDs affect only the firm’s ability to communicate and do business, such as a fire or loss electrical power in the office or building. 2. External SBDs, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services, prevent the operation of the securities markets or a number of firms.

Internal SBDs: In the event of a disruption in Via Global Advisors, LLC;s business operations due an internal SBD, the firm will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving its operations to an alternative location.

If personnel or operations must be moved to an alternate location, the firm anticipates that it will resume regular operations as soon as personnel can access the alternate site.

External SBDs: In the event of a disruption in Via Global Advisors, LLC’s business operations due to an external SBD, the firm will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the affected area, if possible, or by providing customers with alternative communication arrangements, as indicated below, to conduct business or to access their funds and securities.
Via Global Advisors, LLC will attempt to resume business and keep its customers informed regarding relevant events to the best of its ability based on the circumstances.

In all cases, Via Global Advisors, LLC will resume normal business operations as soon as it is able to do so, based on the type and the extent of the disrupting event.

If the significant business disruption is so severe that it prevents us from remaining in business, we will ensure our customers’ prompt access to their funds and securities.

Communications: In the event that you are unable to reach Via Global Advisors, LLC at our main number, please proceed as follows:

  • Contact the firm at the following alternate telephone number: 617-733-9873
  • Access the firm’s website at www.viaglobaladvisors.com
  • Contact the investment manager(s) or custodians directly at the number listed on your most recent statement.

Contact information: Any questions regarding Via Global Advisors, LLC’s Business Continuity Plan should be addressed to: Alan Slaughter, COO & Chief Compliance Officer, via email at as@viaglobaladvisors.com or via telephone at 781-266-6288.