Business Continuity

FULLER     ASSET     MANAGEMENT’S     BUSINESS     CONTINUITY     PLAN     SUMMARY

Fuller Asset Management has developed and implemented a Business Continuity Plan (BCP) that includes redundant data centers and alternate facilities to protect its business processes and technology environment in the event of a significant business disruption. Fuller Asset Management’s policy is to respond to a significant business disruption (SBD) in an effort to safeguard employees’ lives and firm property, make a financial and operational assessment, quickly recover and resume operations, protect the firm’s books and records, and allow our customers to transact business.

The plan addresses business disruptions that may be caused by a local incident or by a regional or market related disaster that applies to many companies. The Plan covers our critical business processes and related employees essential for Fuller Asset Management to continue to conduct business for an interim or temporary period during a business interruption. Every important aspect of Fuller Asset Management’s securities business, including data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business is addressed in this plan.

Fuller Asset Management’s goal is to recover its Critical Business Processes with minimal interruption, depending on the nature of the disruption. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within a 24 hour period. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and presume to recover and resume business within a 24 hour period. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

If after a significant business disruption you cannot contact us as you usually do at 480-553-6352, please use our emergency contact number 480-766-2490 or go to our website at (www.fullerassetmanagement.com) for contact instructions. If you cannot access us through either of those means, and you have a brokerage account carried by one of our clearing firms, you should contact Fidelity Investments via its website (www.fidelity.com) or by telephone at 800-FIDELITY and/or TD Ameritrade via its website (www.tdameritrade.com) or by telephone at 800-669-3900 for instructions on how it may provide prompt access to your funds and securities including accepting buy and sell orders and issuing checks and wires from your account. If your account is held at a mutual fund or insurance company, you should contact the company directly for access to your securities.

Please be advised that our business continuity plan is subject to change and modification. Our firm will update this plan whenever we have a material change to our operations, structure, business, or location or to those of our clearing firm. In addition, our firm will review our plan annually to modify it for any changes. If the plan is modified, we will promptly post the revised summary on our Website. If you have questions about our business continuity planning or would like a written copy of the summary of our BCP, you can contact us at Lawrence@fullerassetmanagement.com or phone our office.