Waterway Capital, LLC (“Waterway”) has developed a Business Continuity Plan (“BCP”) on how our firm will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions are unpredictable, our firm has an obligation to prepare for unforeseen events as they occur. Our BCP is designed to permit our firm to resume operations in a reasonable amount of time at a secure remote location, given the scope and severity of a major event.

Varying Disruptions:

If a business disruption affects only our firm or a specific building within our firm, we will transfer our operations to alternate locations. In a disruption affecting our business district, city, or region, we will transfer our operations to an alternate location outside of the affected area. In either situation, we plan to continue conducting business and notify our clients how to contact us through a voice message reached via our main phone number. To accommodate our recovery time objective, telephone service will continue at the alternate worksites and normal work processes will resume at the alternate worksite. Recovery times may vary depending on the nature and severity of the disruption; however, our recovery time objective for mission critical operations is 0-72 hours. If the significant business disruption is so severe that it prevents us from conducting business, we will update our voice message and/or our website waterwaycap.com.

Contacting Us:

At a minimum, the Waterway BCP is reviewed and updated on an annual basis. Our primary internal and external application providers periodically conduct testing of their own back-up capabilities to ensure that in the event of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need to continue or promptly resume our business. Our BCP is designed to allow us to continue to provide the quality service you have come to expect from Waterway Capital. Should you have any immediate questions regarding the aforementioned or would care for additional information upon the matter, please be in touch directly with our Chief Compliance Officer, Ana Ward at (617) 226-8110.