From Nuveen Investments

Business Continuity

Business Continuity Plan Summary

As a participant in Nuveen’s enterprise-wide Business Continuity Plan (“Plan”), Santa Barbara Asset Management, LLC (SBAM) maintains comprehensive procedures reflecting the Firm’s commitment to plan for and to be prepared for significant business disruptions.  
 
The Plan has been designed to address significant business disruptions affecting the Firm’s business operations and sets forth objectives for safeguarding employees, recovering and resuming operations, protecting books and records, and enabling communications with employees, clients, key service providers, and regulators.
 
The Plan’s primary business recovery strategy is to resume its critical business processes and provide employees with access to key systems and applications from remote locations, with minimal interruption, typically within the same day depending on the nature of the disruption. As such, pursuant to the Plan, SBAM maintains detailed procedures covering the Firm’s business processes and related employees necessary to continue operations during a business interruption.  The most important aspects of SBAM’s investment advisory business are addressed in these procedures, including continued investment management and trading of client accounts, ongoing administrative, operational, technological, and legal/compliance support provided through Nuveen’s shared service platform, and maintaining communication with applicable parties. 
 
In conclusion, the Plan addresses the steps the Firm will take to address our response and recovery from a business disruption in a systematic and organized fashion, while realizing that the effects of any 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.

Effective: March 1, 2013
Amended: February 26, 2018‚Äč