Business Continuity

Huntington Securities, Inc. (“HSI”) has a business continuity plan designed to address a significant business disruption affecting HSI’s business operations and that sets forth HSI’s objectives of keeping employees safe, recovering and resuming operations, protecting books and records, and enabling communications with employees, investors, key service providers, and regulators. The Huntington Capital Markets business continuity plan also contains processes designed to help ensure continuity of HSI’s operations in the event of a business disruption.

HSI is committed to planning for and being prepared for a significant business disruption. HSI’s business continuity plan addresses two types of significant business disruptions: “internal” disruptions, such as a fire in one of HSI’s buildings, affecting only HSI’s ability to communicate and do business, and “external” disruptions, such as an event that might prevent the operation of the securities markets or a number of firms. In either event HSI’s goal will be to recover its critical business processes with minimal interruption, on the same day, if possible, although the length of the disruption is expected to be longer in the event of an external disruption, particularly one affecting the entire securities industry.

The business continuity plan covers HSI’s critical business processes that are essential for HSI to continue to conduct business for a temporary period during a business interruption. Every important aspect of HSI’s securities business, including communications with customers and issuers of securities, order entry and execution, trade clearance and settlement and public and corporate finance, is addressed in these processes.

HSI’s business continuity plan provides for alternative physical location of employees in the event of a business disruption, which may include a remote work location or employees’ residences, depending on the nature of the disruption and the offices affected by it. The plan further provides for financial and operational assessments, identifies mission-critical systems and specifies how these systems would continue to operate in the event of a disruption.

In the event of a business disruption HSI has alternate methods of communication, specified in the business continuity plan, that would allow it to communicate with customers, employees, regulators, business constituents and counterparties. HSI has assessed the ability of its banks, counterparties and critical business constituents to continue their business relationships with HSI in the event of a disruption, and the plan provides for HSI’s establishment of alternative arrangements if one of these parties is unable to provide services to HSI.

Information technology is central to HSI’s operations. HSI has systems in place for the back-up and recovery of information needed to conduct its business. HSI’s business continuity plan identifies the functions, processes and resources necessary to support the restoration and resumption of HSI’s business.

HSI does not have custody of customer funds or securities. In the event of an internal or external significant business disruption, if telephone service is available, customers will continue to have the ability to make purchases and sales despite HSI’s experiencing a significant business disruption, unless the disruption is industry wide in scope.

The effects of a disaster are of course difficult to predict and an industry-wide disruption of systems and processes will pose great business continuity challenges for any firm in the securities industry. There can be no assurance that any plan can address these unforeseen contingencies. However, HSI regularly reviews its business plan with a view to ensuring that it takes into account technological developments and changes in its business operations. HSI will modify this summary from time to time as it reviews the plan. Customers may obtain a written copy of this summary by contacting Huntington Securities, Inc., Chief Compliance Officer, by mail at 200 Public Square, CM235, Cleveland, OH 44114.