BUSINESS CONTINUITY PLAN

Avalon Partners, Inc. is committed to safeguarding the interest of our clients and customers in the event of an emergency or significant business disruption. This Business Continuity Plan Disclosure (the “BCP”) summarizes Avalon’s efforts to mitigate risks inherent with unforeseen business interruptions. The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in the event of an emergency or significant business disruption. This BCP is intended to comply with the rules promulgated by the Financial Industry Regulatory Authority (FINRA).

Communications with our employees in the event of a Disruption

The safety and well-being of our employees is a vital concern. In the event of an emergency or significant business disruption, the firm will communicate with its employees in several different ways. We use a combination of general broadcast and direct targeted outreach. General information such as office closures and operating hours will be posted on the Firm’s internal and external websites.

Redundancy of Mission Critical Information Technology Systems

Avalon has several information technology processing and backup sites that, collectively, provide the redundancy required to protect the firm’s books and records, balance sheet and capital, and provides business continuity and client protection.

Back-Up Trading, Sales and Operations Site

Avalon maintains a backup trading and operations center located within 30 miles from our headquarters. In the event that we are unable to access our primary facility, it may be necessary to relocate certain personal to the backup site. The backup facility is a “hot site” in other words, the site is fully operational at all times. It is equipped with workstations that have redundant computer network connectivity, telephones, printers, fax machines, market data feeds and all other specialty equipment necessary for trading and operations. The functionality of the backup facility is routinely tested by sales, trading and operations personnel.

Protection of Primary Facilities

Protecting the infrastructure of our primary facility is a high priority because it will allow the firm to continue operations in the event of many disaster situations, by permitting our employees to have access to and use of our facilities during that situation.

Disclaimer

The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in the event of an emergency or significant business disruption; however it is not infallible. The plan is designed to work in many different situations; but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. Furthermore, although we are confident in our own preparedness, Avalon has no control over the various entities that we must rely upon in the event of an emergency. Our business continuity plans are tested periodically to ensure readiness; yet each tests may not be able to replicate the actual conditions we experience in a real emergency. This BCP is subject to change without notice. In the event that this BCP is modified, the updated document will be promptly posted on the Avalon internet website Alternatively, customers may obtain an updated hard copy BCP upon request. The information contained in this disclosure is provided by Avalon Partners for informational purposes only. Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any customer agreement between you and Avalon Partners.