Covington Associates Business Continuity Plan

Covington Associates (“Covington” or the “Firm”) is committed to keeping our clients informed and their information protected in the event of a business disruption. Depending on the timing and impact of such an event, Covington will need to be adaptable in responding to actual events as they occur. Our Business Continuity Plan summarized below details how we will respond to a business disruption.

Covington Associates’ plan is designed to restore business operations as quickly as possible while safeguarding our employees and property, protecting the firm’s books and records and allowing our clients to transact business.

Covington Associates’ plan addresses all areas that may be affected by business disruptions of any type: data back-up and recovery, financial and operational assessments, alternative communications with clients, employees, and regulators, alternate locations of employees, critical vendor, contractor, bank and counter-party impact, and regulatory reporting.

Significant business disruptions can range in scope from affecting only Covington Associates or the building that Covington’s business resides in, to the city or entire region where Covington is located. Within these areas, the scope of disruption can vary from minimal to severe. In the event of a disruption to Covington’s office or the building in which Covington resides, Covington Associates will relocate to a local alternate site and resume operations within a few days. In the event of a disruption to the city or region in which Covington is located, Covington will transfer operations and resume business within a week.

In any case, Covington Associates intends to continue business operations as soon as possible and notify you through our website, www.covingtonassociates.com or using one of our client emergency numbers, either (617) 970-7172 or (617) 513-9262.