Business Continuity Plan Summary

Reaves Asset Management has an extensive Business Continuity Plan in place to address potential emergencies and insure uninterrupted operation of its business.

Back-up Site
At the core of the plan is a remote back-up facility, exclusively owned and operated by the company, that will be employed if access to our principal location is unavailable for any reason. The facility is close enough so that it can be operational within a few hours and far enough away so that its electric and communications services and environment are distinct from those serving the company’s principal location. It is fully equipped to take over operation of the business, if required, including all of Reaves Asset Management's mission critical systems, as well as maintaining communication with our clients, vendors and all regulatory authorities. The facility is maintained by SunGuard. Our equipment and processes are self-maintained, updated regularly and periodically tested. We also perform full test on at least an annual basis.

Data Backup
All system and data files are backed up as they are changed and stored offsite at a secure location. This includes our Firm’s books and records.

Virtual Private Network
Key personnel are equipped with special software to allow them to interact with company facilities and back-up facilities from their homes. The facilities are protected from intruders by a state-of-the-art firewall.

Vendor Protection
Finally, we are satisfied that our major vendors, including suppliers of data and custodial and banking services, also have adequate arrangements to permit their continued operation in case of emergency.

Updates
In case of an event requiring Reaves Asset Management to implement its Business Continuity Plan we will post further information on our website at www.reavesassetmanagement.com or www.whreaves.com.

Please contact your account representative or our Compliance department at 201-793-2364 if you have any questions.



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