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Acker Finley Inc.
Executive Summary

Acker Finley Inc's ("Acker Finley") BCP Officer is Marian Buklis, (416) 777-9636, marian@ackerfinley.com. Marian is Vice President and Chief Compliance Officer. The name will be updated in the event of a material change.

Firm Policy

Acker Finley's policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees' lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm�s books and records, and allowing our clients to transact business. In the event that we determine we are unable to continue our business, we will assure clients prompt access to their funds and securities.

Incident Management Plan

In the event that we are forced to leave our building during the course of a business day, all employees will promptly evacuate the building and meet at Starbucks on the corner of York and Adelaide. Employees will receive further instruction from this location.

Our Business Continuity Plan contains a call tree and a standing order: if you think there's a disaster and can't contact anyone proceed to follow the instructions you have been previously given. Employees are instructed to either proceed to the alternate location or remain at home until contacted.

Staff Awareness

We are ensuring that all personnel are continually aware of their responsibilities and know how to remain in contact and what to do in the event of a crisis. The BCP Officer, Marian Buklis, has responsibility for the staff awareness plan.

Acker Finley will maintain copies of our BCP and the annual reviews, and the changes that have been made to it for inspection. Hardcopies will be maintained at both the primary and alternate sites. An electronic copy can be found on our network. An executive summary of our plan is located on our Internet site located at www.ackerfinley.com , under the section entitled "Business Continuity Plan".

Crisis Communication Centre

The IIROC Crisis Communication Centre (CCC) is an information exchange for Investment Industry Regulatory Organization of Canada (IIROC) Dealer Members to be used in the event of a SBD.

The CCC is operated by IIROC and accessible through the IIROC Homepage (BCP CCC) or through the business continuity planning web page which can be accessed through Member Resources. In addition the following link can be used to log in: http://ccc.iiroc.ca/

Business Description

Acker Finley conducts business in equity, fixed income, and derivative securities. We service retail and institutional clients. We also trade securities for our inventory accounts. Acker Finley is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold client funds or securities. We accept and enter orders. We execute orders for TSX listed securities. All other transactions are sent to our carrying broker for execution. Our carrying broker also maintains our clients� accounts, can grant clients access to them, clears and settles all securities transactions, and delivers funds and securities.

Our carrying broker is National Bank Correspondent Network, 77 Bloor Street West 2nd Floor, Toronto, Ontario, M5X 1M2. Our contact person is Tony Greco, Account Manager, (416) 413-3291 tony.greco@td.com. Our carrying broker has also given us the following alternative contact in the event that Tony Greco cannot be reached: Nelli Leite, Service Delivery Manager (416)390-2988 nelli.leite@td.com.

Acker Finley also owns and maintains a proprietary research product know as Quantative Security Analysis (QSA).

Office Locations Head Office

Acker Finley is located at 181 University Ave., Suite 1400, Toronto, Ontario, Canada M5H 3M7. Its main telephone number is (416) 777-9005. We engage in order taking, entry and execution at this location. The QSA server is also kept at this location.

Alternative Physical Location(s) of Employees

In the event of an SBD, we will move our staff from head office to our alternate location at 27 Teddington Park Avenue, Toronto, Ontario M4N 2C4. Its main telephone number is (416) 488-2621, the fax number is (416) 488-3327.

Clients' Access to Funds and Securities

Acker Finley does not maintain custody of clients� funds or securities, which are maintained at our carrying broker, National Bank Correspondent Services. In the event of an internal or external SBD, if our clients are unable to contact us, clients may access their funds and securities by contacting Frank Doria, Account Manager, National Bank Correspondent Services, at (416) 413-3293 or at frank.doria@td.com.

Data Backup & Recovery

Acker Finley maintains its primary hard copy books and records and its electronic records at 181 University Ave., Suite 1400, Toronto, Ontario, Canada M5H 3M7. Marian Buklis (Chief Compliance Officer, (416)777-9636) is responsible for the maintenance of these books and records. All books and records with the exception of trade tickets are stored electronically. We maintain three months of trade tickets on site, the remaining are kept at a readily accessible off-site location.

The firm backs up its electronic data weekly, on the Monday of each week. Once the data is backed up, these hard drives are stored at an off-site location.

In the event of an internal or external SBD, our records will be recovered at our back-up site. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location.

Mission Critical Systems

Acker Finley�s �mission critical systems' are those that ensure prompt and accurate processing and settlement of securities transactions, the maintenance of and access to client accounts, and the maintenance of and access to our proprietary research product QSA.

We have primary responsibility for establishing and maintaining our business relationships with our clients and have sole responsibility for our mission critical functions of order taking, entry and execution for Toronto Stock Exchange (TSX) listed securities, comparison and allocation of orders, and the maintenance of QSA. Our carrying broker provides the execution for all other Canadian and US exchanges, clearance and settlement of securities transactions, the maintenance of and access to client accounts, and the delivery of funds and securities.

In the event of an internal or external SBD, we would be able to continue order execution through IRESS or Triton. We would maintain a connection to ISM to transmit to our carrying broker via the internet. We would back up and recover the QSA system at our alternate location. The recovery of the trading systems and QSA will occur on designated laptop computers. The laptops are pre-loaded with all the back-up programs necessary to conduct trading and back-up. The laptop computers will be stored at our alternate location.

Mission Critical Systems Provided by Our Carrying Broker

Acker Finley relies, by contract, on our carrying broker to provide order execution (for Canadian listed securities other than TSX, and all US securities), order comparison, order allocation, delivery of funds and securities, and access to client accounts, and the maintenance of client accounts.

Communication with Clients, Employees, and Regulators

In the event of an SBD, telephone and fax lines will be re-routed to our alternate location using the call forward feature. The alternate location maintains a 2 line phone system equipped with voicemail. The phone number is (416) 488-2621. The fax number is (416) 488-3327. To activate the call forward feature, our service provider, Allstream must be contacted. Internet connection will be established through Rogers Cable. The alternate location is equipped with a wireless router to allow for internet connection anywhere within the site. We have established a temporary email account for use in the event of an SBD. The email address is ackerfinley@yahoo.com . The address book is pre-loaded with client and key email addresses. In addition, we will be able to access our client database program, Maximizer, once the data recovery process has taken place. The program is pre-loaded on to a laptop computer maintained at the alternate site.

External Dependencies - Service Providers

We have contacted our critical service providers (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm.

Regulatory Reporting

Acker Finley is subject to regulation by: IIROC, OSC, TSX and CNSX. We now file reports using the internet, email, paper copies in the mail, fax, and Echoworx Encrypted email. In the event of an SBD, we will check with our regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. At our alternate location, we will have a laptop computer pre-loaded with the Quickbooks program. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

Updates and Annual Review

Acker Finley will update this plan whenever we have a material change to our operations, structure, business or location or to those of our carrying broker. In addition, our firm will review this BCP annually, on July 31st, to modify it for any changes in our operations, structure, business, or location or those of our carrying broker.

Senior Management Approval

Senior management has approved this Business Continuity Plan as reasonably designed to enable Acker Finley to meet its obligations to clients in the event of an SBD.