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Business Continuity Statement

AllianceBernstein L.P. and its subsidiaries, (collectively “AB” or “we”) have adopted a business continuity strategy that provides for the continuation of business critical functions in the event of a significant business disruption at any of our domestic or international offices including technical failures affecting our applications, data centers, networks and the buildings we occupy. AB also includes measures designed to deal with severe weather, transportation strikes and pandemics as well as any other highly infectious disease, and how the firm will manage business-critical functions during such events. The recovery strategies that we employ are designed to mitigate the impact on clients from significant business disruptions that may affect the firm and its employees.

Our process for developing business resumption strategies and plans involves analysis, planning, implementation, maintenance, testing and awareness. The program is initiated by conducting a Business Impact Analysis (BIA) with each of the business areas. The BIA identifies requirements for key AB employees, applications and services necessary to support the business critical functions for a short duration outage through a longer term outage affecting the office. These documents are part of a “best practices” framework which is reported to a Business Continuity Governance Committee on a periodic basis and reviewed by the individual department heads on an annual basis or when major changes occur.

Business recovery strategies are varied to make appropriate use of both internal and external capabilities and resources. They include external recovery vendor solutions, interoffice relocation, workload shifts, voice redirection and remote access.

Through testing, we verify the resources and requirements identified during the BIA process as necessary for the recovery of all critical business functions, and that such functions operate in accordance with the recovery specifications outlined during the BIA process. While using cost effective and technologically proven systems, equipment and techniques, the firm continually updates both the recovery plans and the necessary technology in order to minimize the time required to recover from a disruption.

No plan is effective without proper documentation. Therefore, AB has developed and maintains business response plans for each office. These plans include mobilization procedures, notification guidelines, call trees and other pertinent information for the businesses as well as plans for crisis management and executive management personnel to ensure proper coordination of command and control activities in the event of an emergency.

Although we have taken steps to develop detailed business continuity plans, unforeseen circumstances may create situations where we are unable to fully recover from a significant business interruption. In a case such as this, AB has plans in place to allow our clients to gain access to their funds and securities through alternative methods which will be managed by AB.