Business Continuity Plan

Sundance Bay’s BCP – which is reviewed, tested regularly, and updated no less than annually, anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the firm’s ability to communicate and do business, such as a fire in the building. External SBDs prevent the operation of the securities markets for several firms and may include events such as terrorist attacks, floods, or wide-scale regional disruptions.

Sundance Bay’s Plan addresses all mission-critical systems, office closing and relocation procedures, and employee alternative physical locations. In addition, regulatory reporting and alternate communications between the adviser and its clients, investors, employees, critical business constituents, banks, counterparties, and others are detailed to preserve uninterrupted communication. The Plan defines data back-up and recovery procedures (hard copy and electronic) and lists formal succession planning in the event of key personnel absence. Further, Sundance Bay requires its primary internal and external vendor systems providers to periodically conduct testing of their own back-up capabilities to verify the prompt provision of the necessary information and applications needed to continue or resume business in an emergency or SBD situation.

Sundance Bay carries out its BCP under the direction of the Disaster Recovery Executive Coordinator (“DREC”). The DREC is responsible for making an immediate preliminary assessment of the nature and extent of any disruption and communicating the firm’s BCP to employees, clients, investors, critical business constituents, and regulators. When an internal or external event, either minor or significant, occurs or appears to be developing, the DREC will be notified. Upon notification or becoming aware of an SBD event, the DREC will implement BCP emergency procedures, secure the headquarters as much as possible, and advise all employees to call the firm’s emergency call line directly @ 801.783.3430 or contact them directly.

If a business disruption affects only Sundance Bay or a specific area within the firm, the adviser will transfer its operations to a local worksite. If a disruption affects the firm’s business district, city, or region, operations will be transferred to an alternate worksite outside the affected area. Telephone service will continue, and regular work processes will resume at its alternate location(s). Sundance Bay will continue conducting business in either situation and notify its clients and investors on maintaining contact through a message recorded on its main phone number and via website posting (www.sundancebay.com).

According to the BCP’s provisions, if an SBD is so severe that it prevents the firm from conducting advisory business, Sundance Bay will update its voice message and website appropriately and inform clients and investors of its status by fax, e-mail, telephone, in person, or other means available and appropriate at the time. If it is determined that the firm cannot continue its business, it will inform clients and investors and provide details concerning next steps and asset access by the same means of communication.