From Nuveen Investments

Business Continuity

Business Continuity Plan Summary

As a participant in Nuveen’s enterprise-wide Business Continuity and Disaster Recovery Plan (“the Plan”), Santa Barbara Asset Management, LLC (“Santa Barbara”) maintains comprehensive procedures reflecting the Firm’s commitment to plan for and to be prepared for significant business disruptions. The Plan addresses significant disruptions to the Firm’s business operations conducted at its Los Angeles location, where nearly all of Santa Barbara’s mission critical processes are conducted. Additionally, the Plan addresses significant interruptions affecting the Firm’s primary production systems which are located in the Chicago area.

The Plan has been designed to cover all critical business processes that are essential for the Firm to continue conducting business during a temporary business interruption. The most important aspects of the Firm’s investment advisory business are addressed in the Plan, including continued management and trading of client portfolios, ongoing operational and legal/compliance support, protecting books and records, and maintaining communication with employees, clients, service providers, and regulators.

The Firm’s primary business recovery strategy is to resume its critical business processes and/or provide access to key critical systems/applications from remote locations, with minimal interruption, as soon as possible, depending on the nature of the disruption. As such, the steps taken, pursuant to the Plan, are designed to ensure that critical information is captured on a daily basis in a manner that can be accessed by employees from remote or alternate locations. Additionally, the Firm has contacted its critical business partners, such as vendors providing essential systems/applications and/or other services and has evaluated their capabilities to provide services in the event of various disruption scenarios. The Firm has additionally considered alternative providers that could be utilized if necessary. Furthermore, the Firm’s information technology operations form a critical part of the Firm’s business and each of its critical business processes. The Plan includes a detailed information technology component which identifies the functions, operations, and resources necessary to support the restoration and resumption of all critical business processes performed at the Firm’s Los Angeles location and to facilitate access to critical systems/applications housed at third-party service providers via an array of communications connectivity. An alternate facility outside of California also serves as a back-up facility supporting resumption of critical in-house systems/applications.

In conclusion, the Plan addresses the steps the Firm will take to address a temporary business disruption in a systematic and organized fashion. However, since the effects of a disaster are difficult to predict and the disruption of systems and processes on an industry-wide basis will pose great challenges for any business continuity plan, there can be no assurance that any plan can address such unforeseen contingencies.

Effective: March 1, 2013