Business Continuity Plan

Business Continuity Plan Disclosure

Niagara International Capital Limited (“Niagara” or the “Firm”) is committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. This Business Continuity Plan Disclosure (the “BCP”) summarizes Niagara’s effort 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 such an event. This BCP is intended to comply with the rules promulgated by the New York Stock Exchange (“NYSE”) and the Financial Industry Regulatory Authority (“FINRA”).

Overview

Niagara International Capital Limited maintains one primary and one alternate facility to house the backbone of our operations and information technology. These two facilities are separated by proximity sufficient to diminish risks posed by local disruptions. This separation is a key element of the Firm’s overall business continuity strategy, allowing us to plan for events at each location individually, since no single event is likely to effect more than one location simultaneously. The benefit of having only one site in each location means our response to an event will be the same whether the event is localized within the Firm itself or city-wide.

Communication 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 telephone, facsimile, e-mail, and mobile phone. General information such as office closures and operating hours will sent via e-mail to registered and non-registered employees on the Firm’s contact lists.

Mission Critical Systems

Our Firm conducts business exclusively in retail corporate securities, retail corporate debt securities, Mutual Fund retail, US Government Securities, Municipal Securities, variable life insurance or annuities, introductions of accredited and institutional investors to hedge funds and as a non-exchange member arranging for transactions in listed securities by an exchange member. Therefore, our only mission critical systems are our internal electronic and paper records, subscription agreement located at our main office. All data on this system is backed up weekly onto a tape drive, and is stored in an appropriately safe location

Protection of Primary Facilities

Protecting the infrastructure of our primary facilities 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 emergency 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, Niagara 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 such 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, customers may obtain an updated hard copy BCP upon request and will provided annually thereafter. The information contained in this disclosure is provided by Niagara 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 Niagara.