Kedem Capital Corporation

Clearing through National Financial Services, a wholly-owned subsidiary of Fidelity Investments

Business Continuity
Planning

Business Continuity Planning

Kedem Capital Corporation has developed a Business Continuity Plan describing how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions are unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information regarding our business continuity plan.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do at (631) 755-3330 or (800) 477-8884, you should call our alternative number (347) 294-0464 or go to our web site at www.kedemcapital.com . If you cannot access us through either of those means, you should contact our clearing firm, National Financial Services at (800) 801-9942. The NFS Business Continuity Statement, as well as other regulatory and supplemental information from NFS, can be found at www.mybrokerageinfo.com .

Our Business Continuity Plan - We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: 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.

Our clearing firm, National Financial Services, backs up their important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments as soon as possible. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions - Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. 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 4 to 24 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business at the earliest time possible. In either situation, we plan to continue in business, transfer operations to our clearing firm, if necessary, and notify you through our web site, www.kedemcapital.com , or our customer emergency number, (347) 294-0464, how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

For more information - If you have questions about our business continuity planning, you can contact us at (631) 755-3330 or (800) 477-8884.