I.      Emergency Contact Persons

 Our firm’s two emergency contact persons are:  Thomas Martinson, President and sole officer, director and employee, 140 Barry Avenue North, Wayzata, Minnesota 55391 (952) 473-4133, or (952) 473-5259, of (612) 670-0200, email tom@martinson.net or tom@martinson-co.net, and Joan M. Martinson, wife of Thomas Martinson and not an employee, officer or director at the same address, (952) 473-5259) or (612) 670-0201, email joan@martinson.net. These names will be updated in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each quarter.

 II.               Firm Policy

 Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business.  In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities. 

 A.   Significant Business Disruptions (SBDs)

Our plan anticipates two kinds of SBDs, internal and external.  Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building.  External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption.  Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

 B.   Approval and Execution Authority

Thomas Martinson, President, a registered principal, is responsible for approving the plan and for conducting the required annual review

 C.   Plan Location and Access

Our firm will maintain copies of its BCP plan at its primary office and back up records location.

 III.           Business Description

Our firm conducts business in advising clients on corporate finance.  As such, we do not perform any type of clearing function for ourself or others.  Furthermore, we do not hold customer funds or securities.  Our only office location is at 140 Barry Avenue North, Wayzata, Minnesota  55391. (952 473 4133).  The office is accessible by land.  We have no mission critical systems other than internet access and access to email which is backed up to hard copy at our primary address and at 317 East Wayzata Boulevard, Wayzata, Minnesota 55391 and via duplicate email servers with Google. Back up of Microsoft Office documents and quarterly accounting system files are also stored at both locations.

IV.           Alternative Physical Location(s) of Employees

 Alternative physical location for conducting business could be any location with internet and or telephone access.

 V.           Customers’ Access to Funds and Securities

 Our firm does not maintain custody of customers’ funds or securities.

 VI.           Data Back-Up and Recovery (Hard Copy and Electronic)

 : Our firm maintains its primary hard copy books and records and its electronic records at

 140 Barry Avenue North

Wayzata, Minnesota 55391

 Thomas Martinson, President, (952) 473-4133 is responsible for the maintenance of these books and records.  Our firm maintains the following document types and forms :  Accounting records for the firm, Microsoft Office documents, and email.

 Our firm maintains its back-up records in electronic form at

317 East Wayzata Boulevard

Wayzata, Minnesota 55391

 These records are stored on disk.  Thomas Martinson, President, (952) 473-4133 is responsible for the maintenance of these back-up books and records.  We back up our records at least every quarter and annually

 In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our back-up site.  If our primary site is inoperable, we will continue operations from our back-up site or an alternate location.  For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.