Claro Advisors Inc. has a plan in place to quickly recover and resume business operations after any significant business disruption. Claro’s Business Continuity Plan addresses such important considerations as to how we safeguard our employees, protect the firm's books and records, and allow our customers to continue to access and transact business in their accounts.

In developing our Business Continuity Plan, Claro has considered the impact of a significant business disruption on critical suppliers, contractors, banks, and counter-parties as well of the potential impact on our regulatory reporting obligations. Specific elements of Claro’s Business Continuity Plan include electronic data back- up and recovery; alternative access to all mission-critical technology systems; financial and operational assessments; alternative means of communicating with customers, employees, critical suppliers, and regulators; alternative physical location of employees; and assuring our customers prompt access to their funds and securities.

Claro's Business Continuity Plan provides for the protection of critical client information and will permit us to resume operations as quickly as possible, given the scope and severity of the disruption. Our Custodian Bank, Fidelity Investments, backs up our important client records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our Fund Administrator and Custodian Bank that its objective is to restore its own operations, complete existing transactions, and accept new transactions and payments within a reasonable period of time. Depending on the severity of the disruption, it is possible that client orders and requests for funds and securities could be delayed during this time. Your product sponsor also maintains records related to your investments and account holdings and backs up important records in accordance with its business continuity plan. For more information on your product sponsor's contingency plan, please contact them directly at the telephone number provided on your statements.

Claro’s plan takes into account both internal and external business disruptions. Internal business disruptions affect only the firm's ability to communicate and do business, such as a fire or loss electrical power in the office or building. In the event of an internal business disruption, the firm will use all efforts to continue to conduct business as usual by utilizing alternative communication methods (such as remote terminal access, cell phones, etc...). If business operations cannot reasonably be conducted at Claro’s current location, Claro has made arrangements for operations to continue at an alternate location. Regular operations will resume as soon as personnel can access the alternate site. External business disruptions are events that cause a wide-scale, regional disruption in essential services; prevent the operation of the securities markets or a number of firms, such as a terrorist attack or a natural disaster. In the event of such a disruption, Claro will make its best attempts to continue to conduct business as usual by moving operations to an alternative location outside the affected area and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances.

In all cases, Claro will resume normal business operations as soon as it is able to do so, based on the type and the extent of the disrupting event. If the business disruption is so severe as to prevent us from remaining in business, our customers will have prompt access to their funds and security.