Kottke Associates Business Continuity and
Disaster Recovery Plan 2011

Kottke Associates LLC (“Kottke”) has developed a Business Continuity and Disaster Recovery Plan that will be activated in the event of a significant business disruption. As these events are unpredictable, our plan is designed to be flexible to actual events as they occur.

Kottke will utilize its web site to post emergency information for general and more specific emergency events when they occur at www.kottkeassociates.com.

Kottke plans to quickly resume business operations after any significant business disruption, and respond by safeguarding employees and property, making financial and operational assessments, protecting the firms’ books and records, and allowing our counterparties to transact business. Our plan is designed to allow our firm to resume operations as quickly as possible, given the type and severity of the business disruption.

Our plan addresses data back up and recovery, mission critical systems, functions and employees, financial and operational assessments, alternative communications, alternative physical locations for employees, and the impact on critical vendors and relationships. Kottke operates its daily processing systems with several redundancies and backup locations, where key employees can operate if regular office locations are unavailable. Significant business disruptions can vary in their scope and severity, affecting just our firm, or a single building, business district, city or an entire region. Our plan provides for the transfer of business functions to backup office locations, as well as allowing some key employees to work from remote locations, or a combination of both.

Our Business Continuity and Disaster Recover Plan is reviewed and audited on a regular basis by a third party, and is distributed to all key employees.