Palisade Capital Management

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Business Continuity Plan

I. Emergency Contact Persons

Palisade’s two emergency contact persons are:

Jeffrey D. Serkes, Chief Operating Officer
Phone: 201-585-5446

Dennison T. Veru, Executive Vice President and Co-Chief Investment Officer
Phone: 201-585-5445

II. Firm Policy

Palisade’s policy is to respond to a Significant Business Disruption (“SBD”) by safeguarding employees’ lives and Firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and communicating with our customers and allowing them to transact business. In the event that Palisade determines that we are unable to continue our business, we will assure customers prompt access to their funds and securities. Although our Firm does not maintain physical custody of customer assets, we will help to provide access to custodial brokers.

A. Significant Business Disruptions

Palisade’s BCP anticipates two kinds of SBDs: internal and external. Internal SBDs only affect Palisade’s ability to communicate and do business, such as a fire or power outage in our building. External SBDs are more macro in nature and prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, significant weather event, or other wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our executing brokers.

B. Approval and Execution Authority

Bradley R. Goldman, Esq., Palisade’s General Counsel and Chief Compliance Officer, is responsible for conducting an annual review of these policies and procedures. Jeffrey D. Serkes and Dennison T. Veru each have the authority to execute this BCP.

C. Plan Location and Access

Palisade will maintain copies of its BCP, annual reviews of the BCP, and the changes that have been made to such plan for inspection. The BCP will also be published on the Firm’s public website

III. Business Description

Palisade is an SEC registered investment adviser that transacts business in public equity, fixed income, convertible securities, private equity, and derivative securities. Palisade does not maintain physical custody of customer funds or securities (though the Firm does maintain legal custody of certain client accounts and private funds under SEC rules). All public securities transactions are sent to executing brokers, which process and settle our orders. Qualified custodians also maintain our customers’ accounts, can grant access to such accounts, and deliver funds and securities to Palisade’s clients. Palisade services both individual and institutional customers, as well as numerous private funds.

IV. Office Locations

Palisade maintains three offices - its headquarters in Fort Lee, New Jersey, and annex offices in Del Mar, California and in West Palm Beach, Florida. All Firm employees are located in Palisade’s New Jersey office, with the exception of one employee who works from Palisade’s Del Mar, California office and two employees who work from their respective homes in Palo Alto, California and Seattle, Washington.

A. Main Office

Palisade’s Headquarters is located at One Bridge Plaza North, Fort Lee, New Jersey 07024, and its primary telephone number is (201) 585-7733. Palisade employees may travel to that office by means of car or bus. All order taking and entry for the trading of securities occurs at this Main Office.

B. Florida Office

Palisade subleases meeting room space (solely for high net worth client meetings) at Northbridge Centre, 515 North Flagler Drive, Suite 808, West Palm Beach, FL 33401. Its telephone number is (561) 832-3558. No Firm employees work at the Florida office on a full time basis as this location is maintained for client meetings on an as-needed basis. No order taking or entry for the trading of securities occurs at the Florida Office.

C. California Office

Palisade maintains an office (primarily for Paul Flather, Portfolio Manager of the Palisade Long Short Alpha Fund) at 1225 Camino Del Mar, Del Mar, California 92014. Its telephone number is (201) 346-5740. Palisade employees working from this location conduct all trading activity through the Firm’s main trading desk located in Fort Lee, New Jersey.

D. Alternative Offices

Palisade has contracted with multiple vendors to provide Firm employees with dedicated office facilities in the event of an SBD at our Main Office. [Employees working from locations other than the Main Office have the ability to work remotely from their homes in the event of a SBD.] Upon the declaration of an SBD, all Firm employees have the ability to conduct business from their homes via remote electronic access to Palisade’s information technology systems (either through Citrix, VPN or remote desktop software). Palisade has also contracted with (i) Agility Recovery Solutions to provide a mobile office (with computers and telephones) in upstate New York within twenty-four hours of the declaration of an SBD (as well as to assist with other disaster-related services), and (ii) Cervalis in Wappinger Falls, New York, to provide a secure secondary alternative office space for a limited number of Firm employees.

V. Client Access to Funds and Securities

Palisade does not maintain physical custody of client funds or securities (though the Firm does maintain legal custody of certain client accounts and private funds under SEC rules), which are maintained at various custodian brokers. In the event of an internal or external SBD, Palisade employees will conduct business (including the purchase and sale of securities) via telephone or web access, as available. Private wealth management clients will also be able to contact custodian brokers directly using the following information:

RBC Advisor Services, a division of RBC Capital Markets, LLC
(212) 437-9936
(212) 437-9937

National Financial Services LLC/
Fidelity Brokerage Services LLC
(800) 544-6666

VI. Data Back-Up and Recovery (Hard Copy and Electronic)

Palisade maintains its primary hard copy and electronic books and records at One Bridge Plaza North, Fort Lee, New Jersey 07024 (both in our headquarters and in a secure storage room located on the 3rd floor of One Bridge Plaza). Vital hard copy documents are routinely converted into electronic format to ensure redundancy in the event of an SBD. Palisade’s Chief Compliance Officer is primarily responsible for the maintenance of such books and records.

Palisade backs up its electronic records to a secure offsite data storage facility in real time utilizing Double Take software.

In the event of an internal or external SBD that causes the loss of vital hard copy books and records, such records will be recovered by using the redundant electronic copies. In the event of the loss of the Firm’s primary electronic records, Palisade will recover such documents from the Firm’s offsite data storage site.

VII. Alternate Communications Between the Firm and Customers, Employees, and Regulators

Palisade communicates with its customers, employees, and regulators in the ordinary course by telephone, e-mail, electronic mobile devices (such as smartphones or ipads), fax, U.S. mail, FedEx, and through in-person visits. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

VIII. Critical Business Constituents, Banks, and Counter-Parties

Palisade has contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services, trading counterparties, banks, and IT vendors), and determined the extent to which we can continue our business relationship with them in light of the occurrence of an internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide Palisade with needed goods or services due to an SBD.

IX. Regulatory Reporting

Palisade is subject to regulation by the SEC and numerous other regulatory bodies. Reports are filed with regulators in the ordinary course via e-mail and the internet. In the event of an SBD that disrupts email or internet access, we will contact the applicable regulators to determine an alternative means of communication.

X. Disclosure of Business Continuity Plan

Palisade discloses in writing a summary of our BCP to customers at account opening, and annually thereafter. The Firm also posts this BCP on the Palisade website and will mail it to customers upon request.

XI. Updates and Annual Review

Palisade will update this BCP whenever we have a material change to our operations, structure, business, personnel or location. In addition, our Firm will review and update this BCP at least annually to reflect changes to the Firm’s operations, structure, business, or location.

XII. Senior Manager Approval

I have approved this Business Continuity Plan as reasonably designed to enable our Firm to meet its obligations to customers in the event of an SBD.

Signed: /s/ Jeffrey D. Serkes Jeffrey D. Serkes
Chief Operating Officer

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One Bridge Plaza, Suite 695, Fort Lee, New Jersey 07024 | (201) 585-7733 | (800) 330-9966 | Get Directions | Contact Us

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