Business Continuity

Firm Policy

The policy of ECS 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 to the extent practicable, allowing our customers to transact business as soon as possible following such SBD. In the event that ECS determines that it is unable to continue its business, the Firm will take steps to assure customers prompt access to investments and underlying issuers of those investments.

Significant Business Disruptions (“SBDs”)

The plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the ability of ECS to communicate and do business, such as a fire in its building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. The response of ECS to an external SBD relies more heavily on other organizations and systems.

BCP Designated Principal – Approval and Execution Authority

Russell Weinberg (the “BCP Designated Principal”) is the registered and designated principal responsible for approving the Plan on behalf of the Firm, and for conducting the required annual review. The BCP Designated Principal, or his (her) designee has the authority to execute this plan.

Plan Location and Access

ECS will maintain copies of the Plan and the annual reviews, and the changes that have been made to it. The Firm will make such records available for inspection by the FINRA and SEC. An electronic copy of the Plan is located on ECS’ main server in the folder named “Business Continuity Plan.”

Updates and Annual Review

ECS will update the Plan whenever there is a material change to the operations, structure, business or location of the Firm. In addition, ECS will review this Plan annually, on or before December 31 of each respective year, to modify it to address any changes in the operations, structure, business or location of the Firm or its branch offices.

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