BUSINESS CONTINUITY PLAN

Business Continuity Plan

Business continuity is a priority for Morgan Creek Capital Management, LLC and its affiliates, including Morgan Creek Capital Distributors, LLC.  In the event of a business disruption, we have plans designed to allow us to continue operations of critical business functions.

In general, Morgan Creek’s policy, as outlined in our business continuity plans, is to respond to a significant business disruption by safeguarding our employees’ lives and protecting firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting the firm’s books and records and allowing our clients to continue to transact business without significant interruption.

Morgan Creek maintains its computer systems at in a multi-tenant cloud, which is hosted at a dedicated co-location facility, separate from our primary facilities.  This primary cloud environment is replicated to a second multi-tenant cloud, which is also hosted at a dedicated co-location facility in another state from the primarily cloud and from Morgan Creek’s offices, such it should not be impacted by a regional disruption.

If Morgan Creek’s office sites are inoperable, we will continue operations from alternate locations by accessing the firm’s computer systems via the internet.

Our firm will update this plan whenever we have a material change in our operations, structure, business or location.  In addition, our firm will review the business continuity plan annually to modify it for any changes in our operations, structure, business or location.