BUSINESS CONTINUITY

White Mountain Capital has developed a Business Continuity Plan to provide procedures for response and recovery in the event of a significant business disruption. The purpose of the plan is to identify responsible personnel in the event of a local or regional disaster, natural or otherwise; safeguard employee lives and firm property; evaluate the situation and initiate appropriate action; recover and resume operations to allow continuation of business; provide customers with access to their funds and securities; and protect books and records. The Plan was developed considering the types of business conducted, systems critical to support business, and geographic dispersion of offices and personnel.

The Plan is designed for implementation to continue conducting business in the event of a disaster that results in a significant business disruption. Whether all or only parts of the Plan are implemented depends on the nature of the disruption. Generally, a significant business disruption would include:

• Destruction of one of White Mountain Capital’s offices or facilities, whether by natural causes or other means
• Loss of life or major injuries to personnel in an office location that disables that office’s ability to conduct business
• Disruption of service from a critical service provider
• Disruption of service due to wide-ranging regional outages such as a power outage

A localized disruption in White Mountain Capital’s office or city would result in a shorter outage than a major regional or national event (e.g., hurricane, widespread power outage or terrorism). In all cases, resumption of business is anticipated within the same business day. White Mountain Capital has made arrangements to safeguard its books and records in the event of a disaster. Should we need to move our operations to an alternate location, we will notify you through our website (www.whitemountaincapital.com) and/or outgoing message on 212-509-0313, our firm’s phone 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 customers’ prompt access to their funds and securities.

White Mountain Capital’s clearing agent maintains customer confirmations and statements under the terms of the clearing agreement. Hilltop Securities Inc (SWST) has developed a disaster and recovery plan to recover and retrieve its records lost in a disaster, including backing up its important records in a geographically separate area.

White Mountain Capital has received assurance from its clearing agent (SWST) that SWST’s business continuity plan is consistent with self-regulatory organization rule requirements and provides adequate protection of customer funds and securities held on behalf of White Mountain Capital’s customers. White Mountain Capital’s senior management will review the clearing firm plan or a summary of its plan at least annually or whenever its plan is changed.