H. C. Denison Co.
Business Continuity Plan Summary Notice

H.C. Denison has developed a Business Continuity Plan (BCP) describing our response to events that could case a significant business disruption (SBD).  Since the timing and impact of disasters and disruptions is unpredictable, we will be flexible in responding to actual events as they occur.  Denison’s recovery time from a SBD will depend on the severity and significance of the event.

CONTACTING US
If after a significant business disruption you cannot contact us as you usually do at (920) 457-9451 or (800) 247-8025, we will post contact information on our website, www.hcdenison.com and/or use the Sheboygan Press and local radio stations to announce contact information. If you cannot access us through these means, you should contact our clearing firm, Hilltop Securities, Inc. at (214) 859-1800 or www.hilltopsecurities.com for instructions on how they may provide assistance to accomplish your requests such as account information, trade requests, or availability of funds.

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 suppliers, contractors, banks 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.

H. C. Denison has made arrangements to operate from back-up facilities in case of a local or regional SBD. The primary site is located in north-central Sheboygan County. Our clearing firm, Hilltop Securities, Inc. backs up important records in a geographically separate area. While every emergency situation poses unique problems based on extreme 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 within the next business day or sooner. Your orders and requests for funds and securities may 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 the next business day.  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 within the next business day.  In any situation, we plan to continue in business, transfer operations to our backup site and/or our clearing firm if necessary, and notify you through our web site www.hcdenison.com on how to contact us.  If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

We provide this BCP Summary Notice upon opening an account with our firm. This plan is subject to modifications. Updated Plan Summary information can be found on our website. Customers may alternatively obtain updated summaries by requesting that a written copy be sent by mail.

To obtain more information about any of these policies please contact us at:
H.C. Denison Company                               
618 N. 7th Street
PO Box 28
Sheboygan, WI   53082-0028       
Phone (920) 457-9451 │ Toll Free (800) 247-8025│ Fax (920) 457-2650                                           
www.hcdenison.com                                                                                                                                              Member SIPC/FINRA