BUSINESS CONTINUITY PLAN Summary and objectives: Provident Investment Management Inc. ("the Company") has developed this plan to ensure, to the best of its ability, that it will restore reasonable functionality in the event of emergency. This document spells out the Company's policies and procedures in the event of loss of use of physical premises, computer equipment and communications capabilities. I. Emergency declaration and initial contact In the event of an emergency, Miles Putnam, as President, will declare an emergency and serve as the primary contact. Miles will attempt to make initial contact with every employee. Should any material impairment in the Company's capabilities occur and Miles not make contact, Dan Boyle or James Skubik may also assume such a role if they have not been contacted within one business day of an apparent emergency. The attached emergency contact list will be updated as necessary. All employees must report changes of address, phone number, cell phone number or primary email address to Miles. If broad-scale interruptions prevent us from locating each other, all personnel should contact Schwab Advisor Services at 855-950-4603. II. Events of emergency a. Fire In the case of a fire, be it in the office of Provident or in the building in which Provident maintains its offices, provided the building is safe to enter, all files, records and computers will be transported to the home of Miles Putnam until new office space is secured. This residence is capable of supporting business and has phone and internet access. The phone of Provident would be forwarded to the temporary location of the business and all clients would be notified via phone of the situation and our method of response. All communication with vendors takes place via phone and internet in our current offices and would be the same in the case of a residence. If the building were not safe to enter and all equipment and files were lost, copies of all account agreements are maintained electronically in SharePoint and accessible from any location. Temporary office space would be secured. New computer equipment would be purchased. b. Power Outage In the case of a power outage, the same procedure outlined in the case of a fire would be used if the outage was local or site specific to our offices. If the outage was regional, we would be forced to move our equipment to a location that had power and internet access in order to run the business. c. Phone/Internet Service Failure Provident utilizes a phone and Internet service provider utilizing always-on, high-speed, connectivity. This technology allows all methods of communication to be on one line and under the responsibility of one vendor. If there was an outage, employees would use cellular phones and instruct our telephone vendor to forward the main number to one of the phones. As long as we have phone and/or internet service, we are able to make trades and manage portfolios. d. Theft All information and documents of a confidential nature are maintained in the office of Provident and locked on a daily basis when the offices are closed. Building management does not have a key to the room. Firm data is maintained in Microsoft 365 rather than on local devices, and access requires individual credentials and multi-factor authentication. Firm-owned equipment, including office workstations and travel laptops, is backed up through Cove Data Protection and can be replaced and restored without data loss. Personal devices used to access firm systems are enrolled in Microsoft Intune; in the event a device is lost or stolen, access is revoked and firm data is remotely wiped from the device. III. Restoration of functionality a. Miles and all available personnel will assess the degree of impaired functionality and determine the next course of action. This section outlines the plans established to deal with a variety of impaired functions. b. Alternative premises i. In the event of loss of use of the current office, Miles' home will be the initial gathering location. ii. The post office and custodians of client assets need to be notified of the new address. c. Critical functions: i. SharePoint/OneDrive files ii. Tamarac Reporting iii. Tamarac portfolio management and trading iv. Highrise client contact manager v. Client trading and cashiering functions (Schwab) vi. Capital IQ Pro from S&P Global vii. Securities analysis (BetterInvesting Online Tools, STKVAL spreadsheet) viii. Office functions (computers, inbound communications, internet connection, corporate accounting) d. Alternative provisions i. SharePoint/OneDrive is in the cloud and accessible at alternate locations. ii. Tamarac is in the cloud and accessible at alternate locations iii. Highrise is in the cloud and accessible at alternate locations iv. Client trading and cashiering functions (Schwab) Client trading and cashiering can be accessed via the internet at advisorservices.schwab.com. In the event of further loss of functionality, trading and cashiering can be handled through any Schwab branch or by phone at Service 800-562-1986 or Trading 877-908-9936 v. Capital IQ is in the cloud and accessible at alternate locations vi. Securities analysis functions and tools are available in the cloud vii. Office functions (computers, inbound communications, internet connection, corporate accounting) 1. Computers – we own and maintain two laptops for travel and emergency use; these laptops contain necessary software to run the mission-critical functions identified in III.c. For temporary use, the Putnam household has two computers with basic functionality, including internet connections. 2. Inbound communications – clients will be instructed to use our 800 number after declaration of emergency. This number is on the letterhead used in all client communications, on our business cards and our web site. Our ADV has been amended to include directions to use our 800 number in the event of emergency. Our telephone carrier will be instructed to port the 800-449-6970 number to an alternative number. 3. Corporate accounting – corporate books are kept on Quickbooks, an off-the-shelf bookkeeping program which is accessible in the cloud. viii. We have been assured by our IT consultant, N2M Technology, that basic functionality can be restored within 24 hours using established backup/restore procedures. IV. Data backup and recovery a. MS 365 Environment Protection – Provident uses Cove Data Protection to backup critical MS 365 services including Exchange Online (emails), OneDrive, and SharePoint. This ensures data is protected against accidental deletion, malicious activity, and application-level failures. b. Workstation Backups – All firm-owned workstations and laptops are backed up through Cove Data Protection, providing recovery capability for endpoint devices and local data. c. Cloud-Based Infrastructure – All production data and systems have been migrated to Microsoft 365 and are maintained in the cloud. On-premises server infrastructure has been retired, reducing operational complexity and on-site infrastructure dependencies. d. Automated Backup Process – Cove Data Protection automatically backs up protected workstations and M365 data on an ongoing basis, ensuring data is continuously protected without manual intervention. e. Off-Site and Immutable Backups – All backups are stored off-site and configured as immutable, protecting against ransomware, accidental deletion, and unauthorized modification. This ensures data integrity and provides a secure recovery point even in the event of a security incident. f. Data Recovery – In the event of data loss, accidental deletion, or corruption, data can be restored from Cove Data Protection backups with minimal business disruption. V. Re-establishment of communications with clients a. Personnel not required to handle securities analysis, portfolio management and client needs will contact all clients as soon as possible and by any means possible. We may not have sufficient telephone connectivity at a backup location, and personnel may need to use cell phone or home telephones. Each client will be given alternative contact information, including the cell phone or home phone number of at least two Company personnel. VI. Other key contacts: Building management: On-site management – Newmark – Daniel Fielding Insurance – Meg Spinale Insurance Agency (State Farm) – 248-647-4870 N2M Technology (technology and telephone support vendor) 248-247-2626 nick.oliverio@n2mtech.com Email help@n2mtech.com to open a N2M service request Envestnet Tamarac: 844-322-2855 Tamarac PortfolioCenter – 800-528-9595 MySwitch: 248-929-9940