Glickenhaus & Co.
Equity, Balanced and Fixed-Income Portfolio Specialists

546 Fifth Avenue
New York, NY 10036
212-953-7800

Business Continuity Plan Summary
The impact of a possible future business interruption is impossible to predict. However, we have assessed our business capacity, and have put together a plan of action. Note, that in the event of a significant regional disruption, our ability to stay in business depends not only on the availability of alternate workspace, but also, among other things, on the survival of telecommunications carrier infrastructure, mass transit capabilities, and firm personnel. During a crisis, clients should refer to our website www.glickenhaus.com for information.

FIRM POLICY
Glickenhaus & Co. is a registered Broker-Dealer and Investment Adviser headquartered at 546 Fifth Avenue, New York, NY. Glickenhaus, in coordination with our clearing firm, has a dedicated business continuity team which will work under a set of operating principles that govern how we manage our customers, employees, facilities, systems, and procedures on a day-to-day basis to prepare the Firm in the event of a disaster.

In the event of a significant business disruption rendering our current location inaccessible, our strategy for continuing business is to first ensure the safety and security of all employees, and then to continue critical business operations at a predefined alternate site.

Our Business Continuity Plan is maintained at our main office with printed copies distributed to critical staff.
INCIDENT RESPONSE
Our Incident Response process is maintained by each Department Head, each with a specific set of roles and responsibilities during an incident (including, but not limited to, incident assessment and disaster declaration, recovery coordination, business strategy, technology recovery, logistics and communications).

Our headquarters building maintains security 24 hours a day, 7 days a week. Building security personnel monitor all visitors entering the building.
ALTERNATE EMPLOYEE COMMUNICATIONS
Glickenhaus & Company established a call tree, whereas Department Heads will be contacted by Senior Management, and each employee will be notified as to what to do by his or her Department Head.

Additionally, notices to both employees and clients will be posted to our website.
ALTERNATE LOCATIONS
In the event of a significant business disruption that effects our headquarters location, key personnel are set up to work from alternate locations. Those employees will continue business and handle client orders and requests.

CLIENT ACCESS TO FUNDS, SECURITIES,
AND HANDLING OF ORDERS
Information for our clients will be posted to our website www.glickenhaus.com.

Additionally, select senior employees who service clients have been instructed to maintain contact information for all our clients, and contact them directly in the event of a disaster.

Access to funds and handling of orders in a significant business disruption would be provided at one of the alternate facilities owned by our clearing firm, Pershing, LLC.. We will make every effort to execute orders; however, depending upon the nature of the disruption, no guarantee can be made that an order will be executed.

If customers are unable to reach a contact at Glickenhaus & Co., they may use Pershing's phone number (201) 413-3635, or their main number, (201) 413-2000 which will be redirected to the Pershing recovery site. Pershing's website will also post information. Their web address is www.pershing.com.
FINANCIAL AND OPERATIONAL ASSESSMENTS
Glickenhaus & Co. believes it can maintain access to its books, records, and securities positions of its customers in the event of a significant business disruption by maintaining this data in the multiple data centers of our clearing firm, Pershing LLC, which provides for recovery both in and out-of-region.

Additionally, books and records not on Pershing's systems are maintained by our Portfolio Management system, Checkfree APL. We maintain both physical and electronic storage facilities outside of New York City.
DATA CENTER STRATEGY &
MISSION CRITICAL APPLICATION RECOVERY
We utilize Pershing LLC for our firm's "mission critical systems" for customer accounts. These systems ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. Neuberger stores both physical and electronic copies of its data with a secure third party located outside the New York metropolitan area. This will allow Neuberger to rebuild the necessary systems and access client data in the event of a large scale disaster in New York City.

Pershing stores both physical and electronic copies of its data on a state-of-the-art internal mainframe disaster recovery capability, based on IBM Geographically Dispersed Parallel Sysplex/eXtended Remote Copy (GDPS/XRC) which provides replication of data between the primary data center outside of Hudson County, NJ, and the secondary data center in Hudson County. Pershing maintains that these systems can be restarted and operational in less than four hours with less than five minutes of data loss. Pershing is the world’s largest and most efficient mirrored data center using IBM mainframes and storage devices as of this writing. In addition, tape capabilities are supported and replicated in both the primary and recovery centers in native tape via robotic Automated Tape Libraries (ATLs) and Virtual (VTS) tape subsystems.

Pershing maintains three data centers that are continuously operational. One data center is located in Florham Park, NJ, one at the main location in Jersey City, NJ, and also at Harborside, their second location in Jersey City.
CRITICAL BUSINESS CONSTITUENTS, BANKS
AND COUNTER-PARTIES
Through its Business Continuity Plan, Glickenhaus expects that it will maintain connectivity with all of its critical counter-parties. However, in the event of a regional or wide-scale outage, Glickenhaus & Co.'s ability to transact business with any critical bank or counter-party is dependant upon that organization's ability to perform its own recovery in a timely and effective way.

REGULATORY REPORTING AND COMMUNICATIONS
We believe that we will be able to issue our standard regulatory reports in the event of a significant business disruption. Glickenhaus & Co. will communicate with regulators using all available methods.

Glickenhaus has satisfied NASD Rule 3520 and NYSE Rule 446(g) by supplying said entities with emergency contact information that can be used in the event of a significant business disruption.
DISCLAIMER
Glickenhaus & Co. asserts that, to the best of its knowledge, all the information contained in this document is accurate, and that Glickenhaus has created a business continuity plan that meets industry standards and regulatory requirements. In the event of an actual significant business disruption, Glickenhaus will make every reasonable effort to enact this plan as written. However, this plan is highly dependent upon critical infrastructure and resources that Glickenhaus & Co. maintains no control over, including, but not limited to: electricity, telecommunications, water, external exchanges, market utilities, and clearing houses. Glickenhaus & Co. cannot guarantee that it will be able to fully implement the plan herein if a significant business disruption results in substantial loss of life.