Business Continuity Plan

Kopernik has a Business Continuity Plan (the “Plan”) which provides for the Firm to continue its business activities, notwithstanding a significant business disruption (a “SBD”). Among other things, the Plan identifies Kopernik’s “mission critical systems” and seeks to ensure that those systems, which involve the prompt and accurate processing of transactions in securities (and other financial instruments), calculation of fund net asset values, fund capital accounting, and fund subscriptions and redemptions, will continue notwithstanding a SBD.

If a SBD were to occur, Kopernik would employ a group text so that senior management could reach all employees quickly. The Plan provides for affected staff to remain at home and work via Kopernik’s remote access systems. If certain affected employees are unable to work from home for an extended time frame, they would be transported to a pre-determined alternative location.

All Kopernik mission critical systems are web-based systems provided by independent vendors, and the Firm has confirmed that each vendor of a mission critical system (e.g., SEI, Bloomberg) has back-up facilities and a suitable business continuity plan in place.