Business Continuity Plan

Howard Weil Incorporated ("Howard Weil") maintains a Business Continuity Plan ("BCP") that provides a course of action in the event of a significant disruption to firm business and for the continuation of firm business following such an event. The BCP consists of firm-wide and departmental disaster recovery that was designed by the Howard Weil Incident Management Team ("IMT"). The IMT serves as the central source of coordination and communication in the event of a significant business disruption. The IMT will first ensure the health and safety of our employees and then oversee the re-establishment and continuation of business processes pursuant to the BCP. The IMT is responsible for evaluating the disruption, instituting the appropriate plan of action, and coordinating recovery efforts.

The BCP is designed to address significant business disruptions of varying scope including, but not limited to:
- Howard Weil only business disruption
- Disruption to a single building in which Howard Weil business is conducted
- Disruption to a business district in which Howard Weil business is conducted
- City-wide business disruption
- Regional disruption

In each of these scenarios, Howard Weil's BCP provides for an evaluation of the scope of the business disruption, and sets forth various plans of action and back-up facilities for the continuation of the firm's business, as well as the alternative means for the dissemination of information to employees and clients. The BCP serves as a guide that addresses how Howard Weil will continue to conduct business during each of the above scenarios, to the extent that is possible pursuant to the IMT's evaluation. It is Howard Weil's intention to minimize the recovery time necessary to resume operations.

In the unlikely event that the IMT declares that Howard Weil is unable to continue business following a significant business disruption, the IMT would oversee and direct how the firm would proceed. Customers should be assured that they will have prompt access to their funds and securities through Howard Weil's back-up systems.

Howard Weil conducts regular testing of the recovery of its systems and back-up facilities in order to ensure that clients can conduct normal business. This also ensures that the clients will be able to receive their funds and securities within a reasonable time following a significant business disruption.

If after a significant business disruption, our clients cannot contact us as they usually do via phone or email, clients should call our alternate number, 832-260-6800 or 504-251-7111 or go to our web site at www.howardweil.com. If they are unable to contact us through either of those means, they should contact our clearing firm, National Financial Services, LLC at 617-563-5977 or www.nationalfinancial.com for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash and security transfer transactions for our clients.

This BCP is subject to ongoing modification based on changing circumstances and assessment of need.