Lisanti Capital Growth Business Continuity Plan Notice

Lisanti is committed to providing a consistently high level of service to its clients. Certain events beyond the control of the firm could impact our ability to meet this goal. These events, or significant business disruptions, may include temporary inability to access facilities due to storms or local or regional power outages; natural disasters such as fire, flood, or hurricane; or intentional malicious attacks on facilities, systems, or personnel. In accordance with regulatory requirements, Lisanti has developed and maintains a Business Continuity Plan (BCP) to address the impact of potential significant business disruptions. The BCP has been designed to reasonably enable Lisanti to provide for continued operations of critical functions to meet its obligations to customers.

Lisanti has designated a senior executive in charge of its business continuity program who is responsible for conducting an annual review of the plan. Named business continuity representatives are responsible for maintaining the plan to reflect any material changes to the firm's operations, structure, business, or locations. Additionally, the business continuity representatives are called upon to lead the resumption of operations should a significant business disruption occur.

The Lisanti BCP assesses the financial and operational risks of varying degrees of significant business disruptions, including building, citywide, and regional events. It identifies plans to protect and restore critical business processes, records, data, systems, and facilities. Depending on the nature of the disruption, our goal is to restore the most critical functions within a matter of hours, while less critical functions would be restored within several days. For security reasons, the specific details of our business resumption plan are not disclosed in this notice. However, Lisanti would like its clients to know that our BCP provides for a wide range of business continuance mechanisms, such as power generators, redundant components, systems, and communication technologies, and the implementation of alternate work and computing facilities.

The BCP addresses methods for communicating to customers, employees, counter-parties and other constituents in the event of a disruption, as well as ongoing communication with and reporting to regulators. Finally, in the event that a serious disaster forces Lisanti to discontinue operations, the plan addresses the mechanisms to provide customers with prompt access to their funds.

Lisanti's BCP is subject to periodic review and modification. Should material changes to the plan occur, this notice will be updated accordingly. Customers may request more information regarding the Lisanti BCP by contacting