BUSINESS CONTINUITY PLAN

The Vertical Group has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us:

If after a significant business disruption, you cannot contact us as you usually do at (212) 918-1202, you should go to our website at http://www.vertgrp.com for additional information. The Vertical Group does not maintain custody of your funds. Please contact your prime broker directory if you need access to your account cash and securities.

Our Business Continuity Plan:

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting.

Varying Disruptions:

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within four hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business by the next business day. In either situation, we plan to continue operating, transferring operations to our clearing firm if necessary, and to notify you through our website https://vertgrp.com or our customer emergency number, (212) 918-1202, on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will advise our customers to that effect and provide alternatives in how they may conduct securities transactions.

For more information:

If you have questions about our business continuity planning, or wish to obtain a copy of the plan, you can contact us by telephone at (212) 918-1202 or by email at info@vertgrp.com.