We recognize that there are risks that could disrupt our business processes, and we have developed a business continuity management program to ensure that we are prepared for such risks. This program is supported by our executive management team and is built upon strong governance and active engagement with the business.

Because the timing and impact of disasters and disruptions are unpredictable, we must be flexible in our response to events. Recovery strategies include locally disbursed processing centers, active management of work-from-home capabilities, prioritization of operations functions, and workload swap capabilities. The severity of disruptions can also vary in scope, and this framework is designed to help us manage recovery of critical operations in the following situations:

• Access to the primary location is possible, but a limited number of systems are inoperable.

• Access is not possible, but all systems are fully operational.

• Access is not possible, and all systems are inoperable.

• Access is possible and all systems are fully operational, but there is limited staffing available due to severe weather, transportation issues, or a pandemic outbreak.

Commonwealth and our clearing firms, Fidelity Clearing & Custody Solutions® (FCCS), which provides clearing, custody, and other brokerage services to Commonwealth through National Financial Services LLC (NFS)*, and Pershing back up our important records in separate locations. They maintain plans that include alternative physical locations; alternative means to communicate with customers; backup telecommunications, systems, and data; and employee safety programs.

Commonwealth conducts regular due diligence reviews of our third-party service providers. Contingency plans undergo annual review with business unit sign-off and are tested regularly, incorporating critical processes and hosted applications. Employee safety and notification protocols for internal and external communications, including simulation exercises, are reviewed, updated, and validated annually.

If the disruption is limited to your advisor's local area, you may access your funds and securities and request transactions directly through Commonwealth's Service Centers in Waltham, Massachusetts, and San Diego, California.

• Waltham: 800.251.0080 or 800.237.0081

• San Diego: 877.347.1982 or 877.347.1983

For more information

If you have questions about our business continuity plan, you may write to us at Commonwealth, 29 Sawyer Road, Waltham, MA 02453, Attn: Business Resiliency & Incident Management Department, or call us at 800.237.0081.